London Wider Waste Strategy - London - Greater London Authority

Policy & Partnerships
London Wider Waste Strategy
Background Study
Technical Report to the
Greater London Authority
prepared by
Land Use Consultants
and SLR Consulting Ltd
June 2004

Text copyright
Greater London Authority
City Hall
The Queen’s Walk
London SE1 2AA
June 2004
ISBN
www.london.gov.uk
enquiries 020 7983 4100
minicom 020 7983 4458
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CONTENTS
1. Introduction 1
2. Waste Policy and Legislation 3
3. Sources of advice and assistance 15
4. Commercial and Industrial Waste 19
5. Construction and Demolition Waste 74
6. Special/Hazardous Waste 95
7. Findings and Recommendations 119
Appendix A: Waste policy and legislation 143
European Policy 143
European Legislation 144
Horizontal Legislation 144
Treatment Specific Legislation 144
Stream Specific Legislation 145
UK Policy 147
UK Legislation 148
Appendix B: Consultees for Commercial and Industrial Waste 154
Appendix C: London’s Companies by Size and Sector (Data Based on Small Business
Service Website) 156
Appendix D: Results of Further Analysis of C&I Compositional Data 159
Appendix E: Local Authority C&I Collection and Disposal Survey 163
Appendix F: Consultees for Construction and Demolition Waste 179
Appendix G: Policy, legislative and other measures influencing the high recycling rates
of C&D waste in Germany, Denmark, Belgium and the Netherlands 181
Appendix H: Consultees for Hazardous Wastes 186
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1. Introduction
1.1. Land Use Consultants (LUC) and SLR Consulting Ltd (SLR) were commissioned by the
Greater London Authority (GLA) in March 2004 to undertake a background study on
the management of wider waste to inform the development of a strategy covering all
controlled waste in London. The wider waste strategy is intended to be complementary
to, and build upon the principles and policies laid out in The London Plan: Spatial
Development Strategy for Greater London (February 2004), and Rethinking Rubbish in
London: The Mayor’s Municipal Waste Management Strategy (September 2003). The
term ‘wider waste’ is used in this project to refer to the following controlled waste
streams:
• Commercial and Industrial (C&I) waste, including the commercial component of
municipal waste;
• Construction and Demolition (C&D) waste; and
• Special/Hazardous wastes.
1.2. The objective of the project is to evaluate current management strategies in London for
the controlled waste streams listed above, and to provide sufficient evidence and data
to inform the development of appropriate policies within the context of a strategy for all
wastes.
Scope of the Project
1.3. The scope of the project is to:
• Review, and supplement where possible, existing data and information on controlled
waste in London, making recommendations for further action where necessary.
• Examine existing management practices for controlled wastes in London.
• Undertake a sector based review and consult with key stakeholders.
• Examine effectiveness and applicability of different instruments and measures
utilised to promote more sustainable management of controlled waste.
• Formulate any recommendations for London in line with existing and proposed
policy and legislative frameworks.
Approach
1.4. Data collation and analysis on the management of the three streams of wider waste has
been undertaken by reviewing existing information and data, and consulting with waste
management companies operating in London, research organisations, local authorities
and national government departments and agencies. An analysis of national and
European legislation and policy applying to wider waste has also been carried out.
Examples of good practice and initiatives within the UK and Europe were sought
through consultation with UK trade associations and organisations promoting
sustainable waste management in London, and government agencies in Europe. The
methods used and consultations undertaken are presented in more detail in each
chapter.
Structure of the Technical Report
1.5. This Technical Report sets out the findings of the research and consultations, and
comprises six chapters in addition to this introduction:
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Chapter 2 summarises the principal legislation and policy applying to controlled
waste and identifies some of its strengths and weaknesses in respect to wider waste.
Chapter 3 provides brief descriptions of the trade associations and organisations
promoting and providing assistance for sustainable waste management in
London, whose activities are discussed further in Chapter 4.
Chapter 4 sets out and reviews the collated existing information on the Commercial
and Industrial waste stream in London. Chapter 4 also presents the results of
consultations with waste management companies, recyclers, reprocessors, the
Environment Agency, local authorities, the organisations described in Chapter 3 and
water authorities, that were undertaken to build up a profile of the C&I waste
management industry in London and identify the potential to influence and promote
waste minimisation, recycling and diversion from landfill.
Chapter 5 presents and reviews the collated existing information on the
Construction and Demolition waste stream in London. Chapter 5 also sets out
results of consultations with construction, demolition and waste management and
recycling companies, research organisations and consultants, and the Environment
Agency to address the gaps in the literature review, build up a profile of the C&D waste
management industry and identify the potential applicability of specific measures and
instruments to promote waste minimisation, recycling and diversion from landfill.
Chapter 6 sets out and reviews the collated existing information on the
Special/Hazardous waste stream in London. Results of discussions with the
Environment Agency and the Hazardous Waste Forum during the collation of existing
information are incorporated in this chapter. Questions regarding special/hazardous
waste management were also posed to the waste management companies during
consultations about commercial and industrial waste and construction and demolition
waste.
Chapter 7 summarises the key findings from Chapters 4-6 and presents an overview
of these findings under cross-cutting themes, followed by a summary of the key
findings for each of the three waste streams. The recommendations generated from
the findings in Chapters 4-6 are also listed in Chapter 7 in consecutive order by waste
stream. The resulting actions to be included as part of the development of the GLA’s
‘Wider Wastes’ Strategy are listed in a table. Each action is prioritised and the relevant
parties responsible for the implementation are identified.
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2. Waste Policy and Legislation
Overview
2.1. This chapter summarises the main legislation and policy applying to controlled waste
and identifies some of its strengths and weaknesses in respect of wider wastes.
Appendix A contains further detail on European Directives and UK legislation and
policy applying to controlled waste, including those referred to in this chapter (marked
with*).
2.2. The purpose of this chapter is to consider the extent to which the current waste
planning framework supports or provides opportunities for sustainable management of
wider wastes. Strategic national policy and current London policy are considered first,
to set the scene, followed by a more detailed analysis of current and pending legislation
and initiatives.
Strategic Waste Policy
National Policy
2.3. ‘Waste Strategy 2000’*is the primary Government policy document on waste
management. ‘Waste Strategy 2000’ was followed in 2002 by ‘Waste Not, Want
Not’*, a report from the Prime Minister’s Strategy Unit which had been asked to carry
out a review of Waste Strategy 2000. The specific tasks for this review were :
• to analyse the scale of the challenge posed by growing quantities of household
waste;
• to assess the main causes and drivers behind this growth now and in the future; and
• to devise a strategy, with practical and cost-effective measures for addressing the
challenge, which will put England on a sustainable path for managing future streams
of household waste.
2.4. Although the original terms of reference focused on household waste, the report
included substantial commentary and recommendations on wider wastes in recognition
that wider waste volumes are greater than municipal volumes and that the management
of municipal and wider wastes is interlinked.
2.5. In 2003 the Government Response to ‘Waste Not, Want Not’ broadly accepted the
Strategy Unit’s recommendations and set out the Government’s intended actions.
2.6. Key policy proposals in these documents that are relevant to wider wastes are
summarised below.
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Key policy proposals in ‘Waste Strategy 2000’ (relevant to wider wastes)
• By 2005, to reduce the amount of industrial and commercial waste landfilled to 85%
of 1998 levels.
• To use the Landfill Tax escalator as the key tool to reduce landfill of waste.
• To develop new and stronger markets for recycled materials through the Waste and
Resources Action Programme (WRAP).
• To promote public procurement of recycled products.
• To introduce producer responsibility initiatives beyond existing packaging initiatives
to include end-of-life vehicles, batteries, and waste electrical and electronic
equipment.
• To affirm the use of Best Practicable Environmental Option (BPEO), the proximity
principle, and the waste hierarchy.
Key policy proposals in ‘Waste Not, Want Not’ (relevant to wider wastes and
accepted in principle in the Government’s Response)
• Extend voluntary agreements with industry to reduce waste and increase the use of
recycled materials and the recyclability of products.
• Promote public procurement of recycled products.
• Consider the case for applying incentives such as economic instruments to
encourage environmentally-friendly products.
• Promote the use of secondary resources through BSI standards.
• Finalise central Government targets for the use of recycled materials. All
Departments to also have in place a trained Green Procurement Officer.
• Encourage local authorities to establish environmental procurement policies and set
their own targets.
• Encourage the development of quality standards for compost, ensuring in particular
that the needs of the customer are taken fully into account.
• Increase the Landfill Tax to £35 per tonne for active waste, in the medium term.
• Consider, in 2006/07, the case for banning the landfilling or incineration of
recyclable products.
• Provide guidance to magistrates for prosecution of waste crimes.
• Keep the case for an incineration tax under review, so that the rise in landfill tax
does not promote incineration at the expense of all other options.
• Bring together the literature and evidence on the relative health and environmental
effects of all the different waste management options;
• Promote education and awareness of waste issues via the Waste and Resources
Action Programme (WRAP).
• Develop pilots for more innovative waste management practices in partnership with
industry and local authorities.
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• Set up a delivery taskforce to fill the gap between national policy and local plans.
• Expand the coverage of Envirowise to 20% of UK companies over the next two
years.
• Accelerate the current programme of work to improve delivery of Private Finance
Initiative (PFI) waste projects. 1
• Reform the Landfill Tax Credit Scheme to adopt a more strategic approach to waste,
to tackle priority areas for investment in waste management.
• Redirect landfill tax revenue to incentivise investment in reduction, re-use and
recycling.
• Strengthen waste policy-making, strategic planning, technical, legal and other
services available to DEFRA.
• Allocate addition funding to WRAP.
• Revise PPG10 to ensure all required facilities for recycling residual waste
management can proceed.
• Ensure that Best Value Indicators support waste reduction and recycling.
• Ensure clear definition of all hazardous waste is developed and disseminated
• Assess existing and planned capacity for hazardous waste management and establish
a Hazardous Waste Forum.
• Assess the potential for fly-tipping of hazardous waste in light of legislative
requirements.
Further recommendations specific to commercial and industrial waste:
• Explore the potential for supporting the wider development of waste exchanges.
• Consider the value of mandatory environmental reporting.
• Increase the role of waste minimisation clubs.
• Consider the use of statutory targets for commercial and industrial waste. Consider
increasing targets after 2005 (subject to data availability, and with voluntary
arrangements as the preferred option).
2.7. Some of the proposals in ‘Waste Not, Want Not’ have already been implemented and
others are due to be implemented through legislation currently being developed. Those
already implemented include a stepped increase in Landfill Tax, reform of the Landfill
Tax Credit Scheme, and development of a Sustainable Waste Management Programme
at DEFRA. The recommendation in ‘Waste Not, Want Not’, that an independent body
should bring together the evidence on the relative health and environmental effects of
waste management options has been progressed by the recent publication of the
document Review of Environmental and Health Effects of Waste Management:
Municipal Solid Waste and Similar Wastes. 2
1 PFI projects are mainly relevant to municipal waste streams managed by local authorities, although there could be
spillover benefits to wider waste streams.
2 Review of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes.
Enviros and University of Birmingham, for Defra. May 2004.
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2.8. The national Planning Policy Guidance Note 10* (PPG10) sets out guidance on how the
land-use planning system should contribute to sustainable waste management,
including criteria for siting facilities. The Government is currently reviewing PPG10 in
line with the delivery of the reforms to the planning system, and a consultation draft of
the revised Planning Policy Statement 10 (PPS10) is due out later this year.
2.9. New legislation and regulations developed since ‘Waste Not, Want Not’ are:
• End of life vehicles regulations (2003).
• Waste electrical and electronic equipment regulations (under development).
• The Waste Emissions and Trading Act (2003).
• Hazardous Waste Regulations (to come into force this year).
London Policy
Vision for London
2.10. The Mayor’s vision is “to develop London as an exemplary, sustainable world city, based
on three interwoven themes:
• strong, diverse long term economic growth;
• social inclusiveness to give all Londoners the opportunity to share in London’s
future success;
• fundamental improvements in London’s environment and use of resources.”
Municipal Waste Management Strategy
2.11. Chapter 3 of the Mayor’s Municipal Waste Management Strategy 3 interprets this vision
in relation to municipal waste as:
The Year 2020 Vision for Waste in London
The Mayor’s Vision for Waste in 2020 in London is that London’s municipal waste no
longer compromises a wider vision for London as a sustainable city. To achieve this,
wasteful lifestyle habits must change so that we all produce only the absolute minimum
amounts of waste, and the environment is no longer under pressure from waste. We
need to ensure that municipal waste is managed in a way that minimises the adverse
impact on the local and global environment, and on London communities, economy and
health.
2.12. The Mayor also recognises the need for a wider Strategy to provide a framework for the
planning of all waste management in London. The Municipal Waste Management
Strategy defines a series of objectives that are consistent with national policy and
legislation. These objectives could apply equally to wider waste and are considered to be
a starting point for wider waste policies, as noted in the specification for this project.
Objectives of the Mayor’s Municipal Waste Management Strategy
It is the Mayor’s objective to develop a ‘waste reduction, reuse and recycling-led’,
cohesive and sustainable strategy for the management of London’s waste which will:
3 Rethinking Rubbish in London The Mayor’s Municipal Waste Management Strategy. Greater London Authority.
September 2003.
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• Change the way we use resources so that we waste less. This will require us to deal
with waste in a sustainable way, and people and communities to take responsibility
for their waste.
• Reduce the amount of (municipal) waste produced in London.
• Increase the proportion of London’s (municipal) waste being reused.
• Increase the proportion of London’s (municipal) waste being recycled and ensure
recycling facilities are available for all.
• Ensure that waste is managed in such a way as to minimise the impact on the
environment and health.
• Move London towards becoming more self-sufficient in managing its (municipal)
waste within the region, and towards waste being dealt with as close to the place of
production as possible. 4
• Meet the objectives of the National Waste Strategy and Landfill Directive, and other
European Directives, by reducing the amount of London’s biodegradable municipal
waste sent to landfill and reducing the toxicity of waste.
• Increase capacity of, stabilise and diversify the markets for recyclables in London;
including green purchasing and encouraging redesign of goods and services to
increase consumer choice.
• Maximise opportunities to optimise economic development and job creation
opportunities in the waste management and reprocessing sectors, contribute to the
improvement of the local community, and directly or indirectly improve the health of
Londoners.
• Strategically plan waste facilities for London that meet the needs of the Waste
Strategy and enable its implementation.
• Collect and share data and information on municipal waste management in London,
and other places; the identification and dissemination of best practice will help to
improve performance and reduce inefficiencies.
• Minimise the transport of waste by road and maximise the opportunities for the
sustainable use of rail and water.
• Improve the local environment and street scene environment.
The London Plan
2.13. The London Plan also has a key role in relation to the spatial elements of sustainable
waste management. Cross-cutting policies in the London Plan (see boxes below)
emphasise the proximity principle, set overall recycling targets, and indicate (inter alia)
that boroughs should:
• safeguard existing waste management sites;
• identify new sites, and support proposals, for activities such as recycling,
composting, manufacturing based on recycled materials, and recovery from residual
waste;
• ensure that the provisions of BPEO are applied;
4 These targets are quantified in the London Plan (see next section), rising from 75% self-sufficiency in 2010 to
85% in 2020.
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• where waste cannot be dealt with locally, promote waste facilities that have good
access to river or rail transhipments;
• forecast waste arisings by stream and forecast imports and exports of waste.
Policy 4A.1 Waste strategic policy and targets
In order to meet the national policy aim that most waste should be treated or disposed
of within the region in which it is produced (regional self-sufficiency) the Mayor will
work in partnership with the London boroughs, the Environment Agency, statutory
waste disposal authorities and operators to ensure that facilities with sufficient capacity
to manage 75 per cent (16 million tonnes) of waste arising within London are provided
by 2010, rising to 80 per cent (19 million tonnes) by 2015 and 85 per cent (22.5 million
tonnes) by 2020. An early alteration to this plan will seek to bring forward regional self
sufficiency targets for individual waste streams.
The Mayor will work in partnership with the Government, boroughs, Environment
Agency, statutory waste disposal authorities and operators to minimise the level of
waste generated, increase re-use and recycling and composting of waste and reduce
landfill disposal. Boroughs should ensure that land resources are available to implement
the Mayor’s Municipal Waste Management Strategy, Waste Strategy 2000, the Landfill
Directive and other EU directives on waste.
The Mayor will work in partnership with the waste authorities, Environment Agency and
operators to exceed recycling or composting levels in household waste of:
25 per cent by 2005
30 per cent by 2010
33 per cent by 2015.
The minimum quantities represented by those targets are 1 million tonnes in 2005, 1.35
million tonnes in 2010 and 1.65 million tonnes in 2015. This would leave some 3.05
million tonnes in 2005, 3.1 million tonnes in 2010 and 3.25 million tonnes in 2015 to be
dealt with by other means, with a declining reliance on landfill and an increasing use of
new and emerging technologies.
Having regard to the existing incineration capacity in London and with a view to
encouraging an increase in waste minimisation, recycling, composting and the
development of new and emerging advanced conversion technologies for waste, the
Mayor will consider these waste management methods in preference to any increase in
mass-burn incineration capacity. Each case, however, will be treated on its individual
merits. The aim is that current incinerator capacity will, over the lifetime of this plan,
become orientated towards non-recyclable residual waste.
Policy 4A.2 Spatial policies for waste management
In support of the Mayor’s Municipal Waste Management Strategy, the proximity
principle and the need to plan for all waste streams, UDP policies should:
• safeguard all existing waste management sites (unless appropriate compensatory
provision is made);
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• identify new sites in suitable locations for new facilities, such as Civic Amenity sites,
construction and demolition waste recycling plants and closed vessel composting;
• require the provision of suitable waste and recycling storage facilities in all new
developments;
• ensure that the principles of Best Practical Environmental Option are applied;
• support appropriate developments for manufacturing related to recycled waste
• support treatment facilities to recover value from residual waste
• where waste cannot be dealt with locally, promote waste facilities that have good
access to river or rail transport
• identify and forecast for the period covered by the UDP total waste arisings, that is
controlled wastes that include municipal waste and also commercial, industrial,
hazardous and inert arisings, and the amount of waste that will be imported or
exported.
The Mayor will promote the co-ordination of the boroughs’ waste policies by bringing
forward, as an early alteration to this plan, strategic guidance which will evaluate the
adequacy of existing strategically important waste management and disposal facilities to
meet London’s future needs, both for municipal and other waste streams, and identify
the number and type of new or enhanced facilities required to meet those needs and
the opportunities for the broad location of such facilities. This guidance will provide
sufficient sub-regional guidance, including the disposal of waste arisings from the
central sub-region, to inform the preparation of SRDFs and UDPs. Until the alteration of
this plan is brought forward, the Mayor will work with boroughs to identify strategically
important sites and will expect boroughs to apply the provisions set out in this Policy
and Policies 4A.1 and 4A.3 in bringing forward development plans and in considering
development proposals. He will also work with the South East England and East of
England regional authorities to co-ordinate strategic waste management across the
three regions.
Policy 4A.3 Criteria for the selection of sites for waste management and
disposal
UDP policies should incorporate the following criteria to identify sites and allocate
sufficient land for waste management and disposal:
• proximity to source of waste;
• the nature of activity proposed and its scale;
• the environmental impact on surrounding areas, particularly noise, emissions, odour
and visual impact;
• the transport impact, particularly the use of rail and water transport
• primarily using sites that are located on Preferred Industrial Locations or existing
waste management locations.
The Mayor will keep these criteria under review, and SRDFs should reflect the need for
any sub-regional interpretation.
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Policies of neighbouring regions
2.14. The Regional Waste Management Strategies of neighbouring regions are of significance
for London’s waste management as significant waste transfers occur between regions.
Although waste travels in both directions, the overall effect is a net export of waste
from London, particularly to the South East England and East of England regions.
2.15. The South East England Regional Assembly published ’No Time To Waste: Proposed
Alterations to RPG South East – Regional Waste Management Strategy’ in March 2004.
The equivalent document for the East of England is the ’East of England Regional Waste
Management Strategy’ (2002). Both strategies contain policies to reduce the disposal
of London’s waste at sites in their regions.
2.16. The East of England Regional Assembly proposes in Policy 3 to only accept the import
of waste from outside the Region in very special circumstances after 2010. Only
residues from waste processing in London will be acceptable in landfills in the East of
England region, and new non-landfill waste facilities dealing primarily with waste from
outside the Region will not be permitted unless there is a clear benefit to the Region.
The implementability of this policy and the achievement of regional self-sufficiency
within the East of England, South East and London regions, is currently being
considered in another study 5 looking at inter-regional waste movements.
2.17. The South East of England makes provision for a declining amount of London’s waste to
landfill and, after 2016, Policy W3 states that waste authorities and waste management
companies “will only provide for residual waste that has been subject to recovery
processes or from which value cannot be recovered. Provision for recovery and
processing capacity for London’s waste should only be made where there is a proven
need, with demonstrable benefits to the region…A net balance in movement of
materials for recovery and reprocessing between the region and London should be in
place by 2016.”
European Legislation and Policy Initiatives
2.18. European waste legislation can be considered in three categories:
• Horizontal legislation that establishes the overall framework, including definitions
and general principles.
• Treatment-specific legislation relating to particular waste treatment options, such as
incineration.
• Waste stream-specific legislation relating to individual streams such as WEEE, ELVs
and batteries.
2.19. The overarching framework is provided by the Waste Framework Directive* (WFD)
(1975, revised in 1991 and 1996) which sets out the policy principles for waste
management by Member States. The WFD requires Member States to give priority to
waste prevention and to encourage re-use and recovery of waste, to protect the
environment and human health, to develop waste management plans and to establish a
system for the authorisation of waste management installations. The Hazardous Waste
Directive (HWD) (1991) provides further specific requirements to complement the WFD
in relation to hazardous waste, including requirements for permitting of installations
handling hazardous waste, controls on transport and record-keeping and tracking
5 Assessment of Regional Waste Movements is due to be published at the end of August 2004 by M.E.L Research
Ltd.
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equirements. The various treatment-specific and waste stream-specific Directives build
on the basic framework of the WFD and HWD.
2.20. In July 2002 the European Parliament published ‘Environment 2010: Our Future, Our
Choice – The Sixth Environment Action Programme of the European Community’*
(EAP). This identifies four priority areas for action, one of which is ‘sustainable use of
natural resources and management of wastes’. Waste management also has strong
linkages to other priority areas of tackling climate change, environment and health and
(perhaps less directly) nature and biodiversity. The EAP includes objectives, targets and
actions which are reproduced below. The objectives and targets are, in general, more
ambitious than current UK policy.
Objectives
• To decouple the generation of waste from economic growth and achieve a
significant overall reduction in the volumes of waste generated through improved
waste prevention initiatives, better resource efficiency, and a shift to more
sustainable consumption patterns.
For wastes that are still generated, to achieve a situation where:
• the wastes are non-hazardous or at least present only very low risks to the
environment and our health;
• the majority of the wastes are either reintroduced into the economic cycle,
especially by recycling, or are returned to the environment in a useful (e.g.
composting) or harmless form;
• the quantities of waste that still need to go to final disposal are reduced to an
absolute minimum and are safely destroyed or disposed of;
• waste is treated as closely as possible to where it is generated.
Targets
Within a general strategy of waste prevention and increased recycling, to achieve in the
lifetime of the programme a significant reduction in the quantity of waste going to final
disposal and in the volumes of hazardous waste generated:
• reduce the quantity of waste going to final disposal by around 20% by 2010
compared to 2000, and in the order of 50% by 2050;
• reduce the volumes of hazardous waste generated by around 20% by 2010
compared to 2000 and in the order of 50% by 2020.
Proposed actions with relevance to waste in the EU 6 th
Environmental Action Programme
• Thematic Strategy on the sustainable use of resources.
• Integrate waste prevention objectives and criteria into the Community’s Integrated
Product Policy and the Community Strategy on Chemicals.
• Revised Directive on sludges.
• Recommendation on construction and demolition wastes.
• Legislative initiative on biodegradable wastes.
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• A Thematic Strategy on waste recycling to include the following types of actions:
Identify which wastes should be recycled as a priority, based on criteria which are linked
to the resource management priorities and to the results of analyses that identify where
recycling produces an obvious net environmental benefit, and to the ease and cost of
recycling the wastes.
Formulate policies and measures that ensure that the collection and recycling of these
priority waste streams occurs, including indicative recycling targets and monitoring
systems to track and compare progress by Member States.
Identify policies and instruments to encourage the creation of markets for recycled
materials.
2.21. In response to the last of these proposals, in May 2003 the European Commission
adopted an interim Communication entitled ‘Towards a Thematic Strategy on the
Prevention and Recycling of Waste’. The objective was ‘to launch a process of
consultation of the Community institutions and of waste management stakeholders to
contribute to the development of a comprehensive and consistent policy on waste
prevention and recycling.’ Section 5 of the Communication introduced a framework for
the future thematic strategy and highlighted the main issues for discussion, on which
stakeholder comments were invited.
2.22. Broadly, the Communication proposed that the future Thematic Strategy should be
structured around four ‘building blocks’:
• Block 1. Core instruments to promote waste prevention.
• Block 2. Core instruments to promote waste recycling.
• Block 3. Measures to close the waste recycling standards gap.
• Block 4. Accompanying measures to promote waste prevention and recycling.
2.23. Waste prevention instruments referred to in the Communication include economic
instruments such as pricing, information campaigns, the ‘Registration, Evaluation and
Authorisation of Chemicals (REACH)’ initiative, waste management plans at the level of
sectors or individual enterprises (e.g. through the Eco-Management and Audit Scheme,
EMAS), although the Communication notes that in general there are not many practical
examples of instruments which could lead to significant quantitative reductions of waste
generation and in which the Community could play a role. The communication also
notes the potential for qualitative prevention of waste, such as replacing hazardous
materials in manufacturing with less hazardous materials, possibly implemented through
the IPPC permitting system.
2.24. Waste recycling instruments referred to include landfill taxes (noting the need for
complementary measures to prevent all waste being diverted to incineration), improved
producer responsibility, tradable certificates (noting the UK’s implementation of these
for packaging waste and biodegradable MSW), incentive systems, and prescriptive
instruments such as landfill bans for certain wastes.
2.25. Waste recycling standard instruments are measures to ensure a level playing field
between recycling and other waste operations. Instruments referred to include
extension of the IPPC Directive to the whole waste sector, determination of quality
standards for recycling, and the possibility of setting EU-wide emission limits for some
processes.
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2.26. Accompanying measures referred to include improving the legal framework (such as the
definitions of the terms ‘waste’, ‘recovery’ and ‘disposal’), promoting research and
development and technology demonstration and development, and measures to
promote demand for recycled materials.
2.27. Following the consultation on the Towards a Thematic Strategy document a series of
stakeholder meetings has been held. The first of these was in February 2004 and
further meetings were held in April 2004. A date for publication of a revised
Communication on the Thematic Strategy was expected by the end of this year, but has
been pushed back to Spring 2005.
2.28. The direct impacts on the UK waste management situation of a Thematic Strategy on
Prevention and Recycling of Waste are difficult to anticipate. Some of the proposals in
the Communication are regulatory and if carried through would need to be transposed
into UK law. Others relate to promoting or facilitating action, especially those proposals
relating to waste reduction rather than recycling, and these may well have little
immediate impact although they would reinforce aspects of current UK policy contained
in ‘Waste Strategy 2000’ and ‘Waste Not, Want Not’.
2.29. Other proposed actions in the 6 th EAP relating to waste, such as the proposal for a
recommendation on construction and demolition wastes, have yet to develop into
concrete proposals and will need to be monitored and reacted to as they proceed.
2.30. The proposed ‘Thematic Strategy on Sustainable Use of Natural Resources’ is also
potentially of fundamental importance to waste management as its overall objective is
to decouple economic growth from resource use and pollution. In October 2003 the
Commission adopted a Communication entitled ‘Towards a Thematic Strategy on the
Sustainable Use of Natural Resources’, but at present there are few concrete proposals
and the work programme has so far focused on theoretical issues in this very complex
topic.
2.31. In summary, current and emerging EU policy on waste and natural resources indicates
the intention to pursue ambitious targets. While a range of policy instruments are being
considered to bridge the gap between intention and reality it is too early to identify the
preferred choice of instruments, the flexibility that will remain to Member States in
choosing among them, and timeframes for implementation. The publication of the
‘Thematic Strategy on the Prevention and Recycling of Waste’ consultation draft should
provide greater clarity on some aspects of policy.
Waste Streams
2.32. The remainder of this chapter briefly assesses the status of waste legislation, policy and
economic instruments in relation to the main ‘wider wastes’ streams: i.e. commercial and
industrial, construction and demolition, and hazardous wastes.
Commercial and Industrial Waste
2.33. As noted in the brief for this study, management of commercial and industrial waste
(C&I) is largely market driven. Larger businesses are sensitive to the costs of waste
generation and disposal and are often open to alternative approaches, either on purely
economic grounds or as part of a broader Environmental Management System approach.
By contrast smaller operators generally treat waste management as an unavoidable cost
of doing business and have little time and resources to invest in alternative approaches.
Where waste disposal is delivered as part of a fully serviced facilities contract as for
many offices in London, there is even less direct economic incentive for action.
13

2.34. Legislation applying to specific types of C&I waste includes the following:
• Packaging waste, through the Producer Responsibility (Packaging Waste)
Regulations 1997*, is the most regulated waste type within the C&I waste stream.
However the Regulations have little direct impact on smaller companies below the
turnover and volume thresholds, being £2m and 50 tonnes of packaging per annum.
• The Hazardous Waste Regulations* to be introduced in mid-2004 will require some
wastes, such as monitor screens, to be diverted from the general C&I stream into the
hazardous waste stream.
• The new Batteries Directive which is to replace the Batteries and Accumulators
Directive* later in 2004, is expected to set a collection target of 95% of industrial
batteries and to require 55% of collected battery materials to be recycled, and will
have to be transposed into UK law.
• The End of Life Vehicles Regulations 2003* will require producers to take back or
provide for disposal of vehicles at the end of their useful lives.
2.35. The Landfill Tax Regulations 1996* provide a cost incentive which works to discourage
landfilling of C&I waste to an extent, particularly waste which is defined as ‘active waste’
and is subject to a higher charge.
2.36. The Landfill Regulations 2002* require that certain waste types are not disposed of in
landfills, such as hazardous waste (unless in a hazardous waste landfill), liquid wastes,
whole tyres (from 2003), and shredded tyres (from 2006). While applying in the first
instance to the disposal contractor, the Regulations have an upstream effect on waste
generators who must segregate such wastes for appropriate treatment or disposal.
Construction and Demolition Waste
2.37. Construction and demolition (C&D) waste management is also largely market driven.
The main legislative requirements relate to contaminated soil from brownfield sites,
which is generally classified as hazardous waste, and asbestos waste. The Producer
Responsibility Regulations 2002* also apply to packaging generated at construction
sites.
2.38. The Aggregates Levy* (implemented under the Finance Act 2001) affects the
management of C&D waste by increasing the cost of virgin aggregates (currently by an
increase of £1.60 per tonne) and thus provides some incentive for re-use and recycling
existing aggregate materials. The Landfill Tax also provides an incentive through the
cost of disposal of waste in landfills (£10/tonne for ‘active’ waste, and £2/tonne for
‘inactive’ (inert) waste). The relatively high transport and disposal costs for C&D waste,
due to the large quantities generated, provide a further financial incentive for re-use
and recycling.
Hazardous Waste
2.39. The hazardous waste chapter of this report describes the specific legislation applying to
such waste, which is much more extensive than that applying to C&I or C&D waste. The
existing Special Waste Regulations 1996* are to be replaced by the Hazardous Waste
Regulations* in mid-2004, which will increase the volume of waste requiring
management as hazardous waste with a commensurate reduction in the general C&I
waste stream. At the same time, the Landfill Regulations 2002* will prevent co-disposal
of hazardous and non-hazardous wastes from July 2004 and thus limit the disposal
options available.
14

3. Sources of advice and assistance
3.1. The array of bodies operating in London, with roles in promoting sustainable waste
management, is somewhat confusing to the outside observer and probably also
confusing to the businesses they are aiming to assist. These bodies include national
organisations, and organisations operating only in London.
3.2. The bodies described below provide facilitation, financial assistance, or other assistance
such as advice to promote sustainable waste management. To date, the greatest levels
of assistance have been provided where the waste materials concerned are from
municipal waste collections or where an operation is seen as a pilot or flagship for the
waste recycling and reprocessing industry. In other cases, such as recycling of metals
and paper from commercial and industrial sources and most recycling of construction
and demolition waste, there is little direct assistance to the businesses involved but a
range of other facilitation services may be available. There is also an emerging trend to
provide greater support for SMEs involved in recycling and reprocessing, in addition to
the larger operations which are typically associated with major waste sector businesses.
National bodies and initiatives
3.3. The following bodies operate nationally.
3.4. The Waste and Resources Action Programme (WRAP) was established in 2001 to
promote sustainable waste management, in response to Waste Strategy 2000. WRAP
gained additional responsibilities following the Strategy Unit review of Waste Not, Want
Not. Funded by DEFRA, the DTI and the devolved administrations of Scotland, Wales
and Northern Ireland, WRAP’s mission is “to accelerate resource efficiency by creating
stable and efficient markets for recycled materials and products [and] removing barriers
to waste minimisation, re-use and recycling”.
3.5. WRAP’s Revised Business Plan (2004 – 2006) sets out the following work programmes: 6
• market development for six material streams (aggregates, glass, organics, paper,
plastics, and wood), with targets for increasing the national processing capacity for
each stream;
• business development in the recycling sector (a target of £10 million additional
investment per year) and provision of advice to businesses;
• promoting the procurement of recycled materials and products by local authorities
and target business sectors;
• regional market development for recycled materials;
• improvement of local authority recycling collections through training and advice;
• communication and awareness raising aimed at the public;
• promoting waste minimisation in households (through composting and reusable
nappies) and waste minimisation in the retail sector.
3.6. Envirowise is a government-funded programme offering free, independent advice on
environmental issues. It is operated by AEA Technology in Partnership with TTI on
contract to the Department of Trade and Industry with contribution from DEFRA. It was
started in the early 1990s and has saved businesses over £797 million 7 . At present it
6 This is a summary of the text in the Business Plan.
7 Source: Envirowise web-site www.envirowise.gov.uk
15

addresses eight main environmental issues 8 , and has targeted 13 9 industrial and one
commercial (retail) sector.
3.7. Waste Watch is an independent not-for-profit organisation funded by central
government, charitable trusts, the corporate sector, individuals, local authorities, and
the national lottery. It works in partnership with a range of public and private
organisations and NGOs and is active in research, policy development and public
education as well as working with business. Wastebusters is its environmental
consultancy service for businesses, and Waste Watch Business Network (WWBN) is a
not-for-profit membership organisation working to help businesses and organisations
save money and increase efficiency through waste reduction. WWBN currently operates
in the London boroughs of Camden, Haringey, Islington, Barnet, Harrow, Hillingdon and
within 5 miles of Heathrow Airport. It also operates the ResourceXchange waste
materials exchange service.
3.8. The Environment Agency promotes waste minimisation and recycling to businesses as
part of IPPC permitting and hazardous waste regulation, in addition to its role in
processing licences for waste facilities. The Agency also provides more general
environmental advice to businesses, notably through its online NetRegs information
resource.
3.9. Business Link has a London office (Business Link for London) that provides a range of
advisory services to businesses. Environmental advice, including waste management
and minimisation, is part of the advice package offered. Business Link also operates
Envirolink, a specialist environmental advisory service owned by the local Business
Links in Bedfordshire and Luton, Cambridgeshire, Essex, Hertfordshire, Norfolk and
Suffolk. There are currently no plans to extend it to London, although its website
provides generally available advice such as best practice guidance.
3.10. The Environmental Services Association (ESA) represents the UK’s waste
management sector. ESA works with government, Parliament and regulators to bring
about a sustainable waste management system for the UK. ESA produces a wide variety
of waste-related information, both for its members and for the public. As well as
specialised reports, ESA produces briefings and policy statements on issues which affect
the waste management industry.
3.11. The Chartered Institution of Wastes Management (CIWM) is the professional body
for the waste management industry, which represents over 6,000 members mostly in the
UK, but also overseas. The CIWM sets the professional standards for individuals
working in the waste management industry and has various grades of membership
determined by education, qualification and experience. The CIWM provides conference,
exhibition, training and technical publication services to the waste management
industry. It also works towards advancing the scientific and technical aspects of waste
management for safeguarding the environment.
London bodies and initiatives
3.12. The following bodies’ activities are specific to London.
8 Cleaner design, cleaner technology, environmental management systems, legislation, packaging, solvents and
VOCs, waste minimisation, and water and effluent.
9 Ceramics, chemical, electronics, engineering, food and drink, foundries, furniture, glass, metal finishing, paper
and board, plastics and rubber, printing and textiles.
16

3.13. London Waste Action (LWA) was formed in 1997 by the Association of Local
Government and London First, to raise the profile of sustainable waste management and
improve waste minimisation and recycling in London. A company with a board including
public sector, private sector and NGO representatives, one of LWA’s main roles is
allocating the London Recycling Fund. The fund is mainly applied to assist waste
authorities meet their statutory recycling targets. LWA also facilitated dialogue between
businesses, the public and local authorities in the lead-up to the Mayor’s Municipal
Waste Strategy.
3.14. London Remade was formed in 2000 to build on the success of LWA in improving
recycling collection rates by stimulating use of the resulting materials. Like LWA it is
constituted as a company with a public and private sector board. London Remade
facilitates the reprocessing of recyclables into materials of an acceptable and consistent
quality and facilitates the use of these materials (and products made from them) by
London businesses and public sector organisations. London Remade’s objectives and
activities align strongly with WRAP’s national programmes.
3.15. London Remade also administers the Mayor’s Green Procurement Code, which now has
320 members including small and large businesses, NGOs, London Boroughs, other
public sector organisations such as schools. The Code requires businesses and public
sector organisations to sign up to a staged set of commitments to procuring recycled
materials and products, in a drive to stimulate local markets for London’s waste
materials.
3.16. The London Development Agency (LDA) has a key role in promoting sustainable
economic development in London and through its SRB programme has provided £5.4
million funding to London Remade from 2000-2004. The LDA draft economic
development strategy Sustaining Success: Developing London’s Economy, is a revision
to the existing economic strategy and aims to integrate economic, social and
environmental objectives. Consultation on the draft economic development strategy
closed in April 2004,. The draft strategy’s first goal, investment in infrastructure and
places, includes specific actions to:
• (4d) Take action to encourage developers and all businesses to adopt
environmentally friendly goods and services.
• (4e) Support the adoption of sustainable construction and design and address the
strategic location needs of waste, recycling and other environmental industries.
3.17. The LDA also commissioned the report Green Alchemy, Turning Green to Gold: Creating
Resource from London’s Waste (November 2003) as part of its sustainable development
function. This examined possible ways that interventions in resource efficiency and
recycling could help to achieve the LDA’s wider policy goals such as wealth and
employment creation, social progress and environmental improvements. The report
identified market development opportunities for paper, organics, glass, WEEE, wood,
tyres and ELVs. It concluded that WEEE and ELV reprocessing should be given the
highest priority in London, based on factors such as the strength of regulatory drivers,
job creation potential, amenity effects and the amounts of land required.
3.18. London First is a business membership organisation supported by over 300 of the
capital’s major businesses and public organisations. It acts as a voice for London
business in the sustainability debate and has commissioned research on London’s
ecological footprint and a Triple Bottom Line for London. It is also a founding partner
of London Waste Action.
17

3.19. The London Regional Technical Advisory Body (RTAB) is a group of representatives
of London waste planning authorities, the waste management industry and the
Environment Agency convened by the GLA. The Government advised all Regional
Planning Bodies (of which the GLA is one) to convene officer-level RTABs to help in the
formulation of Regional Planning Guidance. The London RTAB prepares information
and advice on the provision of waste management to inform waste planning policy in
London.
3.20. The London Sustainability Exchange was established to bring people together from
different sectors to approach the challenges of making London sustainable. It identifies
opportunities for strategic partnerships and promotes sharing of knowledge and ideas.
Its current projects include a Sustainable Construction Project and research on
motivational factors for environmental action, although this research has not yet
specifically extended to waste issues.
3.21. The London Community Recycling Network (LCRN) is a not for profit organisation
that was fully established in 2000 in-line with the national umbrella organisation
Community Recycling Network UK which promotes community-based sustainable waste
management. The LCRN supports and represents London’s voluntary and community
groups working in the recycling sector (‘Community Recyclers’). Community Recyclers
assist local authorities in meeting their household waste recycling and composting
targets. LCRN works with municipal and commercial sectors in four main areas:
• Recycling – collection and recycling of household and commercial dry recyclables
• Composting – providing services and support for composting of organic waste
• Re-use – target manufactured goods that can be refurbished, repaired or
reprocessed
• Reduction – providing services and support for minimising waste
3.22. The London Boroughs in their role as waste collection authorities also clearly have a
key role, or potential role, in promoting sustainable waste management to those
businesses that they service and work with.
3.23. The current and planned activities of these various bodies are returned to in more detail
in the next Chapter.
18

4. Commercial and Industrial Waste
Introduction
4.1. The aim of this part of the project was to evaluate the current management strategies
for commercial and industrial wastes in London, building upon the existing knowledge
base, to enable and inform the development of appropriate policies within the context
of a wider strategy for this waste stream. The specific objectives are listed below. A
summary of the key findings from this chapter is presented in Chapter 7.
Identify and engage with key stakeholders, to include:
• Consultation with the waste management companies operating in London to review commercial
and industrial collection and disposal contracts in place, specifically in terms of tonnages,
management, and customer range (with regard to sectors).
• Consultation with London Local Authorities offering commercial waste collection services, to
establish tonnages, management, and customer range (with regard to sectors), and where
possible establish future intentions with regard to the provision of this service.
• Evaluation of sector based activity, utilizing existing data sources to: identify sectors that are
most prolific in London; engage with relevant stakeholders, government bodies and Trade
Associations to review their sectors waste generation and management; establish whether
projections can be made, or should be made, in terms of specific growth areas, major employers,
or sectors targeted by legislation and policy with regard to waste management.
• Evaluation of SME activity in London, developing a profile of the size of this sector, waste
generation and management options.
• Assessment of different measures taken by Local Authorities to prevent mixing of household
and commercial waste and make recommendations of good practice.
• Assessment of the effectiveness to date and potential applicability of specific measures and
instruments to promote waste minimisation, recycling and diversion from landfill, to include:
– the current and potential role of waste exchanges in London and the potential opportunities
available through the promotion of industrial symbiosis;
– the role and impacts of waste minimisation clubs;
– the use of environmental reporting;
– the impact of the Mayor’s Green Procurement Code;
– the use of standards (for example international standards, such as ISO 14001, or national/locally
applied product standards).
4.2. This chapter starts with an overview of the approach that we have used for researching
and analysing commercial and industrial wastes. We then present a literature review of
the background information that has been collected and collated for this chapter. There
then follows three sections on consultations, starting with waste management
companies, then recyclers and reprocessors, and finally with regard to waste transport
by water. We then focus on commercial and industrial wastes from the perspective of
the size of enterprise producing them, first by looking at small and medium sized
enterprises (SMEs) 10 and then large companies, before going on to consider the drivers
for sustainable waste management practices and aids to assist best practice.
10 SMEs are defined as companies with less than 250 employees.
19

4.3. There then follows a section of further analysis where we have applied compositional
data on commercial and industrial arisings to provide an estimate on the likely
composition of the main commercial waste streams. Finally, we have undertaken
consultations with local authorities with regard to their collection and disposal of
commercial and industrial wastes.
Method
4.4. Relevant literature on commercial and industrial wastes in London has been collected
and collated. A literature review was then undertaken to appraise existing information
of relevance to the study and identify concerns and gaps which need to be addressed to
meet the requirements of the brief. These gaps were then addressed through further
research and consultations with waste management companies, research organisations,
local authorities, and the Environment Agency.
4.5. A major part of this study has been based on consultations. This is particularly the case
for this chapter on commercial and industrial wastes. We have approached numerous
companies, public sector agencies, organisations and the London Boroughs. The
timescale for the consultations has been very tight and we have often asked for detailed
discussions and information from consultees, all of which has required their close
attention. In the vast majority of cases, the response from consultees has been
extremely helpful and positive. We would like to take this opportunity to thank all of
those consultees that we approached for their time and input into this project. We very
much value these contributions and acknowledge that this project would not have been
possible without their support. A full list of consultees for this chapter is provided in
Appendix B.
4.6. When compiling this report, we have tried to aggregate comments from consultees to
protect commercially sensitive information, as well as to provide an overall profile of
wider wastes in London. In doing so we trust that we have accurately reflected
consultees comments. Whilst we have consulted with all the organisations that we
originally intended, it is important to note that this report sets out anecdotal
information and opinion from those consultees that wanted to respond only. We are
aware that there may be others who would have liked to have been approached, but we
were precluded from making contacts due to time and resources restrictions.
Literature Review
4.7. This section provides a literature review of the main documents collected and collated at
the start of this study. It is presented document by document.
‘Strategic Waste Management Assessment, London (SWMAL), 2000’,
Environment Agency
4.8. This report, compiled by the Environment Agency (EA), is based on two data sources:
• DEFRA Municipal Waste Survey of 1998/99 (formerly the DETR survey);
• EA National Waste Production Survey of 1998/99 (includes C&I, C&D and
hazardous wastes).
4.9. The DEFRA survey is based on data from questionnaires sent to all Waste Collection
Authorities (WCAs), Waste Disposal Authorities (WDAs) and Unitary Authorities in
England. Information was collected from each local authority including:
• the amounts of municipal waste collected and disposed of;
20

• the levels of recycling and recovery of household and municipal waste;
• the methods of waste containment;
• levels of service provision; and,
• waste collection and disposal contracts.
4.10. All London waste authorities now send their completed questionnaires to the Greater
London Authority, which validates and publishes the data on the capitalwastefacts.com
website.
4.11. The National Waste Production Survey was undertaken by the Environment Agency in
1999, and is believed to be the largest and most comprehensive study of its kind in
Europe. 20,000 companies were contacted, with 18,600 providing responses, including
more than 1200 from London. Each company was asked to provide information on:
• types of waste;
• quantity of waste;
• mixed, special or packaging waste;
• waste form – solid, liquid or sludge;
• waste disposal (or recovery) method;
• the cost of disposal or income from recovery;
• Standard Industrial Classification (SIC);
• number of employees;
• location; and,
• environmental performance.
4.12. The SWMAL provides baseline data for waste arisings, movements and management
methods for commercial and industrial waste produced in London. The main finding
was that an estimated 7.1 million tonnes of industrial and commercial waste was
produced in London 1998/99, with 61% from commercial activities and 39% from
industrial sectors. Of this 7 million tonnes, at least 84% was exported out of London for
disposal or recovery. These figures are summarised in Table 4.1 below.
4.13. The SWMAL also provides a breakdown of the various types of commercial and
industrial wastes generated within different industrial and commercial sectors. From
Table 4.1 it can be seen that some 60% of the C&I waste in London (4.211 million
tonnes) is simply classified as ‘general industrial and commercial waste’. Further,
another 13% (941,000 tonnes) is put into other general categories, i.e. ’other general
and biodegradable’ and ‘contaminated general’. In addition, the ‘inert/C&D’ waste
stream of 152,000 tonnes (2%) could include a wide range of wastes.
21

Table 4.1: Arisings and basic composition of industrial and commercial waste
produced in London (000s tonnes) (from EA National Waste Production Survey
1998-99)
Waste Type Industry
(k tpa)
Commerce
(k tpa)
Total
(k tpa)
%
London
% England
& Wales
Inert/C&D 104 48 152 2.1 6.4
Paper and
card
378 454 832 11.7 15.9
Food 174 61 235 3.3 9.1
General
industrial &
commercial
Other general
&
biodegradable
Metals &
scrap
equipment
Contaminated
general
Mineral
wastes &
residues
Chemical &
other
1,003 3,208 4,211 59.4 14.9
360 313 673 9.5 7.7
140 86 226 3.2 4.7
154 114 268 3.8 6.7
27 4 31 0.4 0.2
400 62 462 6.5 7.8
TOTAL 2740(39%) 4,350(61%) 7,090 99.9 9.5
4.14. Whilst an indication of source and/or composition is provided in Table 4.1 for a number
of waste streams (i.e. paper and card; food; metals and scrap equipment; mineral
wastes and residues; chemical and other), together these account for just 1.8 million
tonnes or 25% of the total commercial and industrial waste stream. Hence, the SWMAL
provides relatively little information on the waste stream or its composition for the
majority (i.e. 75%) of commercial and industrial wastes arising in London.
4.15. The Strategic Waste Management Assessment for London also gives information on the
movement of commercial and industrial waste within the Environment Agency London
sub-region (see Table 4.2). However, the majority (67%) of the movement is
unrecorded. Table 4.2 indicates that of the commercial and industrial waste for which
the destination is recorded, 378,000 tonnes (i.e. 5% of the total) is managed within
London and 1,950,000 tonnes (28% of the total) is managed outside the city. Results
from the inter-regional waste movement study between the East of England, South East
22

and London regions currently being undertaken by M.E.L Research should assist in
providing a clearer picture of the amount of commercial and industrial waste that is
managed outside of London.
Table 4.2: Commercial and Industrial Waste Flows (from SWMA London, 2000)
Environment
Agency
Sub-region
Central
London
Destination of C&I material (000 tonnes)
Central E N SE S W WRWA Outside
City
Unrecorded
Total
15 - 18 3 1 3 17 359 1,059 1,475
East London 1 1 - - - - 131 464 598
North
London
6 - 46 37 11 1 333 1,004 1,440
SE London - 1 - 42 2 - - 189 432 665
South
London
West
London
8 8 12 45 - 194 556 824
- 18 - 8 20 2 519 797 1,364
WRWA 2 17 19 10 226 451 724
Total 30 3 92 58 110 54 31 1,950 4,762 7,090
Note: Central, E, N, SE, S, W, WRWA refer to Central London, East, North, South, West
London and West Riverside Waste Authority.
4.16. Annex 2 of the SWMAL provides a breakdown of commercial and industrial waste
arisings in London by sub-region, sector and waste type. The sectoral analysis is based
upon the SIC industry codes and is presented for 32 individual categories. The
Environment Agency was contacted to discuss this information. They provided a
summary of this data, whereby the sectors have been grouped into 14 headline SIC
groups by London sub-region. A summary of the Environment Agency data is provided
in Table 4.3.
23

Table 4.3: Total commercial and industrial waste in London per sector, 1999
(based on information provided by the Environment Agency from the 1999
National Waste Production Survey)
Sector Sector Name Total Arisings (000 tonnes)
1 Food, drink and tobacco 525.2 (7%)
2 Textiles, wood, paper 628.9 (9%)
3 Chemicals, rubber, mineral products 346.3 (5%)
4 Metals, metal products 102.9 (1%)
5 Other manufacturing 277.1 (4%)
6 Coke, oil, gas, electricity, water 38.2 (0.5%)
7 Transport, storage, communications 581.5 (8%)
8 Miscellaneous 239.6 (3%)
9 Wholesale 537.9 (8%)
10 Retail 928.9 (13%)
11 Hotels, catering 598.8 (8%)
12 Finance 281.8 (4%)
13 Education 296.6 (4%)
14 Other business and public administration 1,706.4 (24%)
Total 7,090.2 (98.5%)
4.17. With regard to the above table, it is interesting to note that wastes from the commercial
sectors (i.e. sectors 9-14) are likely to be similar in composition to municipal solid
waste. In percentage terms, this represents nearly two thirds (61%) of the total
estimated commercial and industrial waste arisings. This is a higher proportion than
may be expected in other areas of the country. In this regard there may be the potential
for a greater degree of integration between the Mayor’s Municipal Waste Management
Strategy and that for wider wastes than applies elsewhere in the country. In particular,
these types of waste management facilities developed to process municipal wastes
would also be suitable for processing these commercial and industrial waste arisings.
4.18. There are a number of potential sources of inaccuracy with regard to the data presented
in the SWMAL as follows:
• Since all the information is based on survey returns rather than absolute data there
is the potential for error due to the level of confidence provided by the sample size.
• With regard to the DEFRA data, a local authority may provide an estimate if it does
not have the required information, and, likewise, DEFRA may estimate data to fill in
any incomplete or missing sections.
24

• Although the Environment Agency sent out 20,000 questionnaires nationally and
responses were received from 18,600 respondents (93%), which is a relatively high
response rate, it should be noted that this data is used to represent all organisations
(business, industry and public sector) of all sizes across all of England and Wales.
Hence, there is a greater potential for inaccuracy when breaking down data by
region or industrial sector due to sample bias.
4.19. The limitations in the SWMAL data should be noted, especially when using it at the
regional (i.e. London) level and when considering sectoral analysis. Caution should be
exercised when quoting the figure of 7.1 million tonnes as an absolute, it should instead
be referred to as an estimate derived by survey methodology. It should also be noted
that this figure is almost six years out of date, and could now be significantly different,
although it is possible that the expected increases in commercial wastes are offset by
decreases in industrial wastes.
4.20. The size of the SWMA update survey currently being carried out is reported to be
smaller than the previous one, although the methodology is believed to be the same.
Data collection work is being carried out in April and May 2004, with reporting planned
for later in 2004.
4.21. Our discussions with the Environment Agency confirm that considerable effort has been
made in the survey to account for regional variations and sample error by statistical
means. Nevertheless, London is underrepresented in the survey and the confidence in
the regional and sectoral analysis for London could be increased by boosting the sample
for London. This would require additional data survey work within London in general,
and for specific industrial sectors which may be otherwise underrepresented in the
survey. While it is acknowledged that there will always be a degree of uncertainty
attached to data obtained by survey, the benefits of additional waste data will provide
(a) a higher level of confidence in the data (for strategy development purposes) and (b)
a more accurate baseline against which to assess the success of a Wider Waste Strategy
in future years.
Recommendation 1: It is recommended that the validity of the data on C&I waste in
London provided by the Environment Agency in the ‘Strategic Waste
Management Assessment, London’ (SWMAL) 2000 is improved by carrying out
further targeted surveys of selected waste streams relevant to London.
Preferably this should be achieved by the GLA approaching the Environment
Agency as a matter of urgency to establish whether their current survey can be
extended to cover these terms. Government should also be lobbied to provide
more resources to the Environment Agency to fund future surveys.
‘Technical Assessment for Waste Management in London’, April 2003, Enviros
4.22. This technical report uses the SWMAL data, which was reviewed above. It provides
arisings and disposal data for commercial and industrial waste, in addition to data on
construction and demolition waste and special/hazardous waste. Basic information on
current major waste transport routes for London’s recyclables is provided, plus a small
amount of information on the movements of C&I wastes. The report also details all
licensed waste facilities both within and outside of London.
4.23. An attempt was made to carry out an exercise using the Environment Agency’s Local
Waste Interrogator database, which is an on-line application designed to help local
authorities extract waste input and capacity data for their own areas. This is based on
site-return data but only provides details of the amount of waste deposited in and
25

around London but not on the quantities generated. Of course, included in these
figures would be a proportion of commercial and industrial waste that was imported
from outside London for treatment and/or reprocessing or disposal. At the time of
writing, the database was experiencing technical difficulties and access was denied
although, for future purposes, this may be a useful tool to track deposits in London
itself.
4.24. Table 4.4 summarises the transfer stations within London that handle household and
commercial wastes. The numbers of facilities are greatest in the east and west of the
City, with 40 and 35 sites in these sub-regions, albeit the smaller number of facilities
elsewhere in London handle an equivalent amount of waste. Transfer stations are
generally clustered in specific areas known to be close to road and rail transport nodes.
Table 4.4: Household/Commercial Waste Transfer Station Capacity (from
Technical Assessment for Waste Management in London, 2003)
London Plan subregion
Number of sites 1 Capacity (000 tonnes)
Central 15 3,508 (25%)
East 40 5,002 (35%)
North 19 1,024 (7%)
South 15 1,498 (11%)
West 35 3,209 (23%)
Total 124 14,241
1. Sites used as transfer stations licensed to handle commercial and industrial wastes.
4.25. There are only a limited number of operational landfills in London. Table 4.5 indicates
that in 2003 there were ten landfill sites accepting inert wastes and eight accepting
non-inert and other wastes. With the exception of one landfill site in the south, all the
landfill provision is in the east and west of London.
Table 4.5: Landfills in London (from Technical Assessment for Waste
Management in London, April, 2003, Enviros)
London Plan
Sub-region
Noninert/other
Inert Closed/Restoration Total
Central 0 0 0 0
East 4 6 4 14
North 0 0 0 0
South 1 0 1 2
West 3 4 10 17
Total 8 10 15 33
26

4.26. London exports a large proportion of its wastes to surrounding areas. These materials
are predominantly managed at landfills in the South East and East of England regions.
Appendix 2 of the Technical Assessment contains details of the known licensed sites in
the South and East of England, in addition to those in Northamptonshire. The
Assessment states that there were 383 non-inert sites and 274 inert sites in these
regions at the time of writing. The commercial and industrial waste flows and arisings
by sub-region within the Technical Assessment are taken from the SWMAL document
and have therefore already been detailed earlier in this chapter.
4.27. The waste arisings data used in the Technical Assessment is only estimated for the base
year of 2000/01, using the SWMA 1998 data. Hence, the same comments detailed
under SWMAL with regard to data accuracy apply (para. 4.19).
‘Waste Options Modelling Technical Report for the London Plan’, Mayor of
London, Feb 2003
4.28. This report is similar to those produced by Regional Technical Advisory Boards (RTABs)
outside of London. It models three options of growth, i.e. using no growth, growth
based on the London Gross Domestic Product (GDP), and growth based on sub-regional
changes in employment. It then uses these to generate options for managing London’s
wastes until 2020. The three options modelled are:
• Option One: Business as Usual
• Option Two: Meeting EU Proposed Targets
• Option Three: Exceeding Targets
4.29. The options modelling was based on the Environment Agency survey of commercial and
industrial waste undertaken in 1998/99 and published in the SWMAL, as discussed
above, with the exception of municipal waste. The total waste arisings were then
projected forward to the base year of 2000, using the method from the Enviros
Technical Assessment. However, in order to ensure that there was no double counting,
the non-household municipal waste arisings were removed from the baseline figures.
4.30. The results of the commercial and industrial waste modelling for 2020 are shown in
detail within the report for each growth rate and modelling option. The preferred
option in the report for managing London’s commercial and industrial waste is Option
Three.
4.31. It should be noted that total waste arisings have been projected forwards from 1998/99
to the base year using the same method as the Enviros Technical Assessment. In
addition, the data used by the Environment Agency is only available at a London level or
EA sub-region level, which varies slightly from the sub-regions used in the London Plan
and therefore the total arisings and disposals figures in the Technical Report being
allocated to London Plan sub-regions on the basis of total employment in 2001.
‘City of Westminster Waste Analysis’, SWAP, April 2001
4.32. This waste analysis was undertaken for the City of Westminster, which collects a large
proportion of commercial waste as part of its municipal waste collections. Given that
the City of Westminster has a higher proportion of offices than many of London’s
boroughs and a relatively high proportion of commercial and industrial waste arisings,
the findings as a whole may be less relevant to many other areas of London. However,
it does provide interesting information regarding waste arisings and composition for
commercial waste as summarised in Table 4.6.
27

Table 4.6: Number and weight of samples for commercial wastes for the SWAP
report (based on SWAP report 2001)
Sector Total number of samples Total weight of samples (kg)
Offices 4 2,141
Retail 11 1,317
Hospitality 26 9,059
Total 41 12,517
4.33. As can be seen from this table, the number of samples for the office sector in particular
is very small, and there are also relatively few for the retail sector, although a higher
weight of samples has been recovered from the former. In comparison, the hospitality
sector has been subjected to a more detailed survey, both in terms of number and
weight of samples.
4.34. The results from the SWAP survey, and particularly for the office and retail sectors,
should be regarded with a certain level of caution due to the relatively small sample
number and weight. Nevertheless, these waste streams are not necessarily expected to
vary a great deal. Further, the survey is recent and detailed in terms of the categories of
waste that it covered. It also was carried out over a year which allowed temporal trends
to be captured. It is the most useful compositional survey that was identified during our
study and hence a summary of the results is presented in Table 4.7 below.
Table 4.7: Composition of retail, hospitality and office sector waste streams in
Westminster 2000/01 (based on SWAP report)
Retail Hospitality Offices
% Tonnes % Tonnes % Tonnes
Paper 27 250.8 11 65.9 65 129
Cardboard 40 371.6 12 71.9 7 139
Glass 3 27.9 41 245.5 5 99
Plastic 13 120.8 7 41.9 8 159
Ferrous metals 1 9.3 2 12 1 20
Non-ferrous
metals
1 9.3 1 6 1 0
Putrescible 9 83.6 20 12 10 199
Textiles 2 18.6 1 6 1 20
Miscellaneous
combustible
2 18.6 1 6 0 0
28

Miscellaneous
non-combustible
Particles passing
through a 20mm
sieve
1 9.3 0 0 1 20
1 9.3 4 24 1 20
Total 100 928.9 100 598.8 100 1,988.2
Note: Tonnes are in 000 tonnes. Figures have been rounded up.
4.35. From Table 4.7 it can be seen that paper and cardboard make up a very large proportion
of both office (73%), and retail wastes (67%). Whilst this is also an important waste
stream within the hospitality sector (23%), glass is by far the highest with 41%. Glass is
very much lower in retail (3%) and offices (5%). Putrescible wastes are also high in
hospitality (20%) whilst they are half this in office and retail. The other significant
waste stream within these sectors is plastic with 13% in retail, 7% in hospitality and 8%
in offices.
4.36. Consideration should be given to the possible sources of the different wastes identified
in the above tables. A significant amount of the cardboard is expected to come from
packaging in all sectors. A high proportion of plastics are expected to be packaging
wastes in the retail and office sectors, but these are perhaps more likely to be from drink
and food containers in the hospitality sector. The putrescible wastes within offices are
likely to mainly arise from staff canteens, discarded lunches and also hospitality events.
Within retail this will also include food wastes from discarded products, whilst in
hospitality this will also include waste food. This does not include separately collected
cooking oils/fats from pubs and restaurants etc.
4.37. The SWAP report also provides an indication of the amount of each waste stream that is
potentially recyclable and non-recyclable in Westminster based on the survey findings.
This is presented in the Table 4.8.
Table 4.8: Proportion of potentially recyclable elements of retail, hospitality
and office sector waste streams in Westminster 2000/01 (based on SWAP
report)
Material Type
Retail % Hospitality % Offices %
Recyclate(RC) Non-recylate(NR) RC NR RC NR
Paper 20.3 7.2 3.7 7.7 53.6 12.3
Cardboard 37 3.6 9.4 2.1 6.5 0.6
Glass 2.9 0.2 42.4 0.1 4.5 0
Plastic 7 5.9 1.3 5.7 1 6.7
Ferrous metals 0.3 0.3 1.5 0.6 0.3 0.5
Non-ferrous
metals
0.5 0.1 0.5 0 0.7 0
Putrescible 5 4.2 12.1 8.1 8.3 1.4
Textiles 0 2 0 0.6 0 0.6
Miscellaneous
combustible
0 2.1 0 0.8 0 0.4
Miscellaneous
non-combustible
0 0.4 0 0.3 0 1.1
Particles passing 0 1.4 0 3.8 0 1.5
29

through a 20mm
sieve
Total 73 27.4 70.7 29.8 74.9 25.1
Note: Tonnes are in 000 tonnes. Figures have been rounded up
4.38. From Table 4.8 it can be seen that some two thirds of the wastes from each of the three
sectors surveyed is potentially recyclable. However, the materials that are potentially
recyclable vary within each of the sectors. For example, a high proportion of the
potentially recyclable elements of the office waste stream is paper (53.6% of total
wastes), whilst this is lower in retail (20.3% of total wastes) and very little in hospitality
(3.7% of total wastes). Conversely, a high proportion of the potentially recyclable
elements of the hospitality waste stream is glass (42.4% of total wastes), whilst this is
much lower in retail (2.9% of total wastes) and offices (4.5% of total wastes).
4.39. Table 4.8 also shows that the amount of potentially recyclable waste types varies across
the waste streams in Westminster. Taking paper as an example, it can be seen that
twice as much non-recyclable paper is used in the hospitality sector as that which is
potentially recyclable. In comparison, a considerably greater amount of potentially
recyclable paper is used in both the office and retail sectors. Plastics is another
interesting example. In retail, approximately equal proportions of plastic wastes are
potentially recyclable and non-recyclable, whilst a much higher proportion of nonrecyclable
plastics are used in both the hospitality and office sectors.
‘Rethinking Rubbish in London. The Mayor’s Municipal Waste Management
Strategy’, Mayor of London, September 2003
4.40. The Mayor’s strategy is primarily concerned with municipal solid waste. However, this
includes 0.996 million tonnes of collected non-household waste in 2001/02, which
declined slightly to 0.930 million tonnes in 2002/03. This equates to 22% of the total
municipal solid waste generated in London. The strategy also provides data on the
amounts of non-household waste collected for disposal and non-household waste that
is recycled, in addition to the total non-household waste generated within each London
Borough.
4.41. The Greater London Authority and London Remade maintain the Capitalwastefacts.com
website, which presents the data from the DEFRA/GLA annual Municipal Waste
Management Survey Data. It provides data on commercial and industrial wastes
collected by each borough. This is presented at a local and London-wide level for the
amount of non-household waste collected and the number of commercial properties
that waste is collected from.
Other Reports
4.42. We have consulted the London Development Agency and Business Link as part of this
project. The following reports were provided by these organisations and reviewed.
They are addressed in specific sections later in this report.
• London Development Agency, November 2003, ‘Understanding London’s Sectors’.
• London Development Agency, November 2003, ‘Green Alchemy, Turning Green to
Gold: Creating Resource from London’s Waste’.
• Business Link, December 2003, ‘Analysis of VAT Registered Businesses in Greater
London and its Sub-Regions’.
30

• Brook Lyndhurst, March 2004, ‘Sustainable Business Development, Final Report for
the London Development Agency and Business Link for London
4.43. Other waste compositional data will become available on the higher and further
educational sectors later this year as Waste Watch will have completed their Biffawardsponsored
Mass Balance project which is, in part, looking at waste outputs from
educational institutions.
Waste Management Companies Consultations
Approach
4.44. The aim of the consultations was to address the information gaps identified in the
literature review and to provide additional information to build up a profile of the waste
management industry in London. The main objectives were to obtain additional data on
tonnages, management, customer range, and future intentions. It was noted at the
outset that some of this information may be commercially sensitive and hence may not
be made available to us.
4.45. Consultation by telephone was deemed to be the most appropriate approach. This was
due to the short timescale available and the greater flexibility that this approach gave.
Companies were identified through the Environmental Services Association (ESA)
members’ database, available on their website, as well as from SLR’s knowledge of the
industry.
Environmental Services Association (ESA) Website
4.46. This website provides information on private waste management companies within
London. Although its members’ database lists private waste management companies, it
does not provide details as to whether they operate in London or simply have an office
in the city.
4.47. A total of 19 waste management companies were approached. Each company was
initially contacted by telephone to identify the appropriate member of staff who would
be able to answer any questions. Detailed discussions were held with 8 companies,
which included the main ‘household names’ (i.e. BIFFA Waste Services, Cory
Environmental, Cleanaway, Grundon, Onyx and SITA) and limited discussions were held
with a further two companies. A list of consultees is appended (Appendix B).
4.48. Whilst many of the companies contacted were able to provide useful information, the
majority were unwilling or unable to provide even approximate information on tonnages
and composition.
4.49. The responses to our consultations are described below, starting with a general profile
of the industry before looking at arisings, treatment, disposal, and barriers and
opportunities.
Company Profile
4.50. There appears to be no single or easily defined model for waste management companies
in London. Not only do the companies vary in terms of size, facility, and the waste
streams that they handle but, interestingly, some also vary in terms of their national
profile; i.e. some companies operate a different service in London compared to other
areas of the country. For example, there are companies that collect commercial and
industrial and municipal wastes across the country, but who largely concentrate on
municipal wastes in London. Alternatively, one company concentrates on waste
31

handling and transport in London, rather than the collection service that they operate
elsewhere in the UK.
4.51. The companies that responded to our consultations varied in their size of operations in
London from three persons to several thousand. In the majority of cases, the London
operations were part of a national organisation. Some companies are, of course, active
on an international scale. Some companies are independent, whilst others are part of a
wider group. LondonWaste has been formed as a joint venture with half of the
company owned by the North London Waste Authority and half owned by SITA UK.
Many of the companies own their own facilities, whilst others may lease. Some also
operate facilities on behalf of a local authority.
4.52. Most of the consultees had head offices or the control of their London operations
located outside of London, often at a waste disposal facility. However some, such as
LondonWaste and Thames Waste Management, were within London. A large number of
waste management facilities tend to be located on the outer periphery of the city. In
general most companies have transfer stations or MRF facility within the city for the
transfer and bulking up of waste, before it is transported out of the city for disposal or
treatment.
4.53. Most company collection services were focused on a particular industry or geographical
area(s) of London, although two did provide complete coverage of London. This
appears to be largely due to the location of their handling, treatment and disposal
facilities. It may also be due to company acquisition which has provided a focus in a
particular area.
4.54. All the waste management companies with whom we had detailed discussions operate
environmental management systems (EMS) or are in the process of developing them.
All were obtaining certification to ISO 14001 on a site by site basis, concentrating on
operational sites, rather than depots.
Waste Arisings
4.55. Only one company was able to provide a total tonnage for commercial and industrial
arisings from London, which was a relatively small figure compared to the overall
commercial and industrial waste stream in London. The main reason stated for not
supplying information was due to commercial confidentiality. Also, several companies
collect or receive mixed household and commercial wastes on behalf of boroughs and
hence do not specifically identify how much of it is from commercial premises.
4.56. In discussions regarding the large amount of commercial and industrial wastes described
as “general”, one consultee commented that the European Waste Catalogue may
potentially reduce the amount of compositional detail in the future as more waste could
be included in the ‘general’ category.
4.57. With the exception of two companies that did not provide a collection service, all
consultees collected both municipal and commercial and industrial wastes. However,
some companies largely focused on one or the other, whilst some did both.
4.58. It appears that in many cases, the waste management companies transport waste via
transfer stations. However, this again is dependent on the economics; if it is more
economic or efficient to deliver wastes directly to the treatment and disposal facilities,
then collection vehicles will do so. Due to a restricted number of transfer stations within
the City of London, there are a large number of refuse collection vehicles delivering
32

waste directly to the disposal facility. Some of the transfer stations just sorted wastes,
others bulked up, while some did a combination.
4.59. All of the companies also received wastes from other companies at their transfer and
disposal sites. This included other major waste management companies as well as
numerous small companies such as skip hire and builders.
4.60. Not all of the companies handled hazardous wastes. Those that did would typically
handle it through a different operating division to their other waste streams. One
consultee talked of their particular approach to handling fluorescent tubes through a
collection scheme using special containers which were then sent up to a company in
Manchester. The same company also operated a container system for special wastes for
companies to store and dispose of small quantities of different types of special waste.
4.61. Most of the consultees do not handle liquid wastes. The one company that did has a
range of manufacturing clients generating large volumes of waste, through to
individuals who require cesspits in their houses to be emptied. Their main sector is the
food industry. The most common types of liquid wastes collected are food wastes,
cosmetics, oils and glycols, and interceptor wastes. They tend to concentrate on shortterm,
ad-hoc collections, as opposed to long-term regular contracts.
4.62. With one exception (see the section on waste transport by water later in this chapter),
all consultees used road haulage to transport wastes. They all use diesel fuel in their
vehicles, with one company operating a mixed fleet of diesel and liquid petroleum gas
(LPG) fuelled wagons. None of the companies indicated that they used rail, although
this question was not specifically asked to every company.
4.63. In general, none of the consultees had noted any significant trends in the volume or
composition of commercial and industrial wastes, either over recent years or on an
annual cycle.
4.64. One consultee noted that the Local Authority collection varied in that some will be
purely for household and civic amenity sites, whilst others may include commercial and
perhaps industrial premises as well. If it is a High Street collection round it may be cocollection,
in other cases commercial and industrial wastes may be collected separately.
In some locations waste management companies employed to carry out Local Authority
collections are allowed to develop their business and add value to the contract, by
increasing the amount of recycling and using the waste management facilities for their
own purpose, while in other cases this is not allowed. For example, in some areas a
glass collection system operates at weekends from public houses and nightclubs using
the same vehicles and facilities.
4.65. Several consultees indicated that Local Authorities should allow the multiple use of
facilities and vehicles by the waste management companies. This was thought to be
necessary to increase recycling and to help make the most of waste management
facilities that were in short supply in London due to planning difficulties.
Recommendation 2: It is recommended that, wherever feasible, the joint use of waste
collection vehicles and management facilities to handle both municipal waste
and commercial and industrial waste should be encouraged in order to
facilitate increased levels of recycling and to make the maximum use of fixed
assets. However, due care and attention should be paid to the data reporting
requirements to ensure that municipal and non-municipal wastes are treated
separately.
33

4.66. Not surprisingly, all of the waste management companies that collect commercial and
industrial wastes have a very large range of diverse clients, from a corner shop or small
office producing relatively small amounts of waste, to large retailers, major commercial
companies and a range of industries. Of the companies that were able and willing to
give a breakdown, most thought that the approximate split between small and large
accounts was around 50:50.
4.67. All of the major companies were offering some form of total waste management service
in London including waste auditing and waste minimisation advice, and wider activities
such as cleaning and security, as well as waste handling and disposal. It is understood
that in many cases contracts would be set up with incentives to promote sustainable
waste management practices and, in some cases, the waste management company may
also be getting paid for recycling.
4.68. One company commented that they provide a service for one-off events such as
sporting occasions, exhibitions, conferences and concerts. Examples included the
Millennium Dome and events at Wembley. In this regard, they provide a full waste
management service including facilities and personnel as well as waste transport and
recycling/disposal. The waste management contracts for these large events are often
tendered, usually as a one-off contract. Whilst some do include an element of recycling,
perhaps expressed as a target, the perception was that they were nearly always driven
by price and that perhaps only scant attention was paid to recycling. The same
consultee also noted that due to the one-off nature of these contracts there was usually
insufficient opportunity to work with the producer to try and promote more sustainable
waste management practices.
Recommendation 3: In order to advance the promotion of sustainable waste
management practice in London, it is recommended that a best practice guide
be issued relating to the management of waste resulting from large-scale
public events.
4.69. The comment was made that SMEs have perhaps a lower expectation as customers than
larger companies since they expect lower prices with an associated lower standard of
service. Larger SME’s tend to sign up for longer than a year contract (the minimum
length of contract for this consultee). The smaller SMEs arrangements tend to be a lot
more ad-hoc and will shop around for the cheapest contract. The larger enterprises
tend to have waste managers who may be looking for different buying criteria, such as
higher quality, different collection regimes etc, in addition to corporate plans, including
a company environmental policy.
Treatment and Disposal
4.70. All but two of the companies consulted use transfer stations within London for the
bulking up of wastes before transport onwards for processing and disposal. The first
exception is a company with four treatment centres located around the M25 for liquid
wastes which utilise either physical and chemical treatment or anaerobic digestion. The
residues are then disposed of to landfill. The other has a materials recycling facility
(MRF) for the separation of materials which are then sent for recovery and recycling.
4.71. Another company consulted already operates a MRF in London, and a third is proposing
to develop one. One consultee commented that the amounts of waste recovered at
MRFs largely depend on whether the waste is pre-sorted or unsorted when it enters the
MRF; wastes at the former are easier to recover, as recyclables are already sorted, and
hence a much larger proportion is recovered with only a very low percentage of residual
34

wastes going to landfill. Conversely, if waste is unsorted, the proportion of potentially
recyclable materials going to landfill is much higher. Other than the two companies that
operate MRFs, none of the other consultees indicated that they treat wastes prior to
disposal (other than incineration).
4.72. Whilst a number of the companies own and operate their own facilities within London, it
is no surprise that most of the companies tend to have a larger number of disposal
facilities outside London than within given the higher levels of demand on land within
the capital.
4.73. The majority of commercial and industrial wastes handled by waste management
companies are disposed of to landfill or incinerated. Of the companies who gave
figures, the amount of waste landfilled is between 65-70%. After this, incineration is
the main form of disposal for many of the companies. Most of the companies contacted
owned and operated facilities within and outside London. In general, the facilities
within London were primarily depots which acted as a base for collection vehicles and,
to a lesser degree, waste transfer stations. The facilities outside London included
disposal sites (i.e. landfill sites) in addition to depots and waste transfer stations. The
head office functions were also often located outside of London. Most landfills received
wastes from other parties, such as local authorities and commercial collection
companies.
4.74. Some companies also transport a small proportion of their wastes to landfill sites a
considerable distance outside of London, such as Northampton. The manager of a
landfill in Northampton commented that it was rarely economic to transport wastes such
large distance without return loads. In his case, collection vehicles often returned with a
consignment of aggregates from nearby quarries (under a separate contract) which
rendered the overall trip economic. The only exception to this is likely to be in the case
of the transportation of hazardous wastes, which require specialised vehicles. The sites
that were further outside of London were very much more likely to be used for wastes
that had come via transfer stations.
4.75. In general, it appears that the majority of the major waste management companies
consulted are not involved directly in recycling and reprocessing to any great extent in
London. Such activity appears to be largely undertaken by smaller and more specialised
companies. However, one consultee noted that their practices in this regard changed in
different areas of the country; for example they do recycle glass in the north west, but
only a small amount in London. The same company mentioned that they were
considering constructing a facility for food wastes which would centre on a separate
collection service. Smaller specialised companies were contacted, however they were
either unwilling to be involved in consultations or were unable to take time to discuss
their operations.
4.76. One landfill manager commented that a great deal more could be done to remove
paper, cardboard, timber, plastics etc from commercial and industrial waste for recycling
at the transfer stations. He thought that perhaps 75% of incoming wastes were
potentially recyclable. However, he went on to state that the market is not there for
these products and so they continue to be landfilled. He noted that the re-saleable
products such as hardcore, soils and metals are recycled to a much greater extent.
4.77. Apart from commercial and industrial wastes, one waste management company noted
that they did not typically receive a great deal of other non-household wastes such as
construction and demolition waste at their landfills in Essex. This was partially because
35

some construction companies had their own waste transfer stations and crushing
facilities in East London which was more economic than disposal.
4.78. With regard to London’s incinerators, the Edmonton incineration plant has a total
capacity of 500,000 tonnes per annum, while the SELCHP plant capacity is slightly
higher at approximately 510-520,000 tonnes. The waste entering the Edmonton
incinerator is all municipal waste, including some C&I wastes collected as part of the
municipal waste stream. Only specific types of C&I wastes are accepted for incineration;
these are generally wastes that are essentially similar to household wastes, such as
foodstuffs and paper. LondonWaste has to examine each waste stream entering the
plant to ensure that there is the correct mixture of waste for incineration.
4.79. The incineration operation generates ‘bottom ash’ which consists of an ash and scrap
metals. The ash is reprocessed into secondary aggregate which LondonWaste then sell,
and the scrap metals (both ferrous and non-ferrous) are recycled by a third party. An air
pollution control (APC) residue is also produced. This is essentially a lime solution
which is sold to companies who then use it to neutralize industrial acids and in the
process produce filter cake. As a result of these recovery operations, only a tiny fraction
of the incineration residues are sent to landfill.
Barriers and Opportunities
4.80. All of the companies contacted believe that the main barriers to recycling and innovative
treatments at present are financial and/or the lack of stable markets, and the following
comments were made. The recycling markets and the markets for some recyclates tend
to be volatile and vulnerable to change. There are few stable markets and there is,
therefore, a general reluctance to invest in the recycling/processing industry. In
addition, there needs to be a public acceptance of a need to be more sustainable.
Unfortunately, at present, recycled products have a reputation of being of a poorer
quality than those that use virgin materials. Therefore, unless the image and
performance of recycled products is improved this is likely to continue to be the case.
4.81. A number of the consultees believed that the manufacturers of consumer products had
the greatest opportunity for waste prevention in the first instance. Packaging is
thought to be the main opportunity for waste minimisation, but care has to be taken to
ensure that issues such as hygiene and freshness are not compromised. Investment in
how the public views waste and how they buy goods is required. One consultee also
thought that greater investment should be made to educate the public in waste
minimisation and recycling issues.
Recommendation 4: It is recommended that greater use is made of advertising and
other public awareness-raising techniques to reinforce the need for
sustainable waste management practices in relation to packaging and the use
of recycled materials.
4.82. Some consultees commented that legislation is a significant driver at present, with the
Packaging Directive and the Aggregates Tax (for C&D wastes) noted as most likely to
have the biggest impact on non-household wastes.
4.83. The majority of the consultees predicted that the amounts of waste being landfilled
would be reduced as the landfill tax starts to rise at a rate of £3 per tonne/annum, from
2006. This would result in recycling becoming more economically viable for commercial
and industrial businesses.
36

4.84. All of the consultees consider that London does not currently have the capacity to treat
and dispose of the majority of its own waste. The main barrier to this is perceived to
relate to planning issues for waste management and disposal sites. Companies
expressed unwillingness to invest in the promotion of new waste management facilities
within the city due to the financial risks involved and the uncertain outcome of planning
decisions based on the public’s perception of waste management sites. A significant
change was not expected with regard to this issue unless there is an amendment to the
UK planning regulations.
4.85. It is recognised that whilst the public sector has the responsibility for ensuring that
sufficient provision is made for the management of municipal waste, the treatment and
disposal of commercial and industrial waste is largely provided by the private sector. At
present the private waste management sector appears to be adopting a very cautious
approach to the investment in new facilities. This is largely due to concerns about the
planning process combined with uncertainties over the impact of future regulations and
the recyclates market.
4.86. One consultee quoted that there was a tendency for persons ‘outside of the industry’ to
refer to ‘innovative technologies’ as a solution to London’s waste problems, without
having sufficient knowledge of the financial and planning issues that had to be
addressed to bring such plants on stream. It was emphasised that this required
significant up-front investment over several years to pilot technologies without
necessarily the security of knowing whether there will be a sufficient market for the
technology (due to the need of securing future contracts) and whether they will actually
be able to establish the plant at all due to planning issues. As a part of Defra's Waste
Implementation Programme, two funding programmes are being launched to encourage
the take up of new technologies in the treatment of biodegradable municipal solid
waste. The Technology Research & Innovation Fund (TRIF), which is currently at the
Expression of Interest stage, will allocate around £2m to address the current lack of
funding for R&D projects into new technologies.
4.87. Many of the waste management companies commented that, in general, residents and
business do not want waste management facilities located in their neighbourhood. All
also commented that the planning system is very difficult for them to successfully get
developments through and is prohibitive to the development of new waste management
facilities in and around London. In general, companies may well be trying to plan ahead
by five years or more to take into account the timescale for the planning system. Even
for a non-contentious site, they expect two to three years. It is a major issue for them
to plan ahead by such a large timescale, especially as this may be outside of the
timescale for new legislation and it is difficult to identify what types of contracts may be
in place in the medium term and, hence, what return on investment there may be.
4.88. Overall, consultee’s comments suggest that the planning system is not delivering the
conditions necessary for the development of waste management facilities by the private
sector. One consultee also suggested that planning inquiries were likely to find against
development for certain types of technology, such as incineration, as there was a
tendency to side with public opinion and pressure groups rather than taking due
account of scientific evidence.
4.89. One of the waste management companies thought that both the “top-down” and
“bottom-up” approaches were required to initiate change in the industry. They
commented that the government and the GLA should put in place incentives and
regulation to promote sustainable waste management practices. Further, it was
37

necessary that the waste producers combined together to ensure that such practices
were implemented. This included making the best of a given location. They also
thought that this should include making the best use of civic amenity sites by making
them available for receiving trade wastes. They considered that targets are required for
the recycling of commercial and industrial wastes and was concerned that income from
Packaging Recovery Notes (PRNs) is not necessarily going back directly into recycling
and that the producer is also not being encouraged to recycle from the PRNs. A real
change is required such that sites and plans are made on a regional basis; an element of
predictability is required regarding certain facilities so that industry and sustainable
waste management facilities can be located together for mutual benefit.
4.90. One consultee indicated that they offered a service to inform clients of their legal
obligations from a waste management perspective. Interestingly, whilst there was
continual demand for this, they had not been as inundated with enquiries regarding
forthcoming legislation to as great an extent as they had anticipated.
Waste Transport by Water
4.91. This section has been informed by consultations with the waste management companies
as well as the Port of London Authority and British Waterways.
River Thames
4.92. The River Thames is ideal for moving wastes as the cargo is not time sensitive and the
barges can carry up to 1,500 tonnes. The Port of London Authority has confirmed that
the majority of the 800,000 tonnes of waste that are currently transported on the river
is municipal wastes. There are four waste transfer stations under their jurisdiction where
containerised wastes can be put onto the river. Three of these are operated by Cory
Environmental. Cory is the only current operator of waste management services on the
river dealing with municipal contracts. Cleanaway own the fourth waste transfer station,
but do not operate water-borne waste services at present as they do not have any
current contracts in place. Nevertheless, we were informed that Cleanaway are
maintaining their jetty, vessels and infrastructure so that they can bid for future
contracts. There are currently two waste transfer stations where waste can be offloaded
for disposal; i.e. Cory’s landfill at Mucking in Essex and Cleawaway’s landfill at
Rainham in Essex.
4.93. There is considerable potential for getting more waste onto the river since the river is
not operating at capacity, except during periods of high traffic from leisure users during
the summer. Also, only the day-time tide is used for waste transport and hence there is
also the opportunity to use the night-time tide, although this is more expensive due to
shift payments. The exception is Cringle Dock where they operate on a 24 hour basis,
which is useful for taking commercial wastes from public houses and restaurants during
the evening and night.
4.94. However, we were informed that the riverside transfer stations were running at close to
capacity and hence provide the main limitation for increased waste transport by water.
Nevertheless, the Port of London Authority wishes to establish another three waste
transfer stations to provide greater and more regular access to the river. It was
confirmed that the Port of London Authority work closely with the Greater London
Authority and it was noted that the Mayor has a great interest in the increased use of
the river for freight transport and that the two organisations are working together to
bring back some of the non-operational wharfs into use (Port of London, Volume 2,
Number 73, January/February 2004).
38

4.95. The main barriers to increased use in this regard include the availability and
safeguarding of land for future riverside development. It is understood that both the
Port of London Authority and the GLA are active in this regard. It was also considered
that waste management facilities are not often favoured by many residential and
business neighbours.
4.96. Opportunities for waste transport on the river over and above the four transfer stations
are site and project specific and usually relate to construction and demolition activities.
For example, there is discussion about using the river for wastes and/or recyclables from
the Battersea Power Station redevelopment. There is also the possibility that sites such
as Battersea may allow access to the river as a general waste transfer station during the
redevelopment phase and hence provide a temporary (over the medium-term) waste
transfer station. There have been other projects for which the river would have been
ideally suited to the movement of wastes, but were not chosen.
4.97. With regard to specific projects, we were informed that the main difficulty is in
encouraging developers and planning authorities to consider the river for waste
transport early enough in the project. All too often it appears that waste is considered
late on in the planning stage when tender documents may have already been drawn up
and discussions entered into with contractors. Hence, the developers may not be aware
of the potential benefits of using the river until it is too late to incorporate them into
the project.
4.98. In terms of costs, we were informed that road transport usually appears cheaper at first.
This is due to the ease of setting up an operation without the need for so much
infrastructure. However, when the full costs over the life-time of a project are taken
into account, then river transport will often work out cheaper. This is further improved
due to the Mayor’s congestion charging programme. Obviously, there are a range of
wider environmental and social costs associated with getting waste off the roads.
River Lee and London Canals
4.99. British Waterways are actively promoting the use of the broad and narrow canals and
the River Lee in London for the transport of freight, with particular emphasis on wastes.
Capacity is dependent upon water volume as well as payload 11 . An individual vessel can
carry perhaps 80-100 tonnes which although much smaller than the equivalent on the
Thames, is still several lorry loads. In addition, fuel consumption is lower than by road
and even though speeds are low, they do not compare too badly with road transport in
London.
4.100. A pilot study is currently being carried out on the River Lee with regard to waste
transport by Waste by Water Limited with a government grant. A special vessel is used
which facilitates the direct transfer of a compacted waste module from lorry to boat
without the need for traditional transfer facilities; this reduces costs and increases
efficiencies. The water-borne part of the journey is from the end of the waste collection
round to the Edmonton Incinerator. Whilst the canal portion of the waste collection is
relatively small in terms of the overall contract value, it reduces lorry movements and
helps to make the overall package more efficient. If the trial is successful, this is
expected to be used for the London Borough of Hackney’s municipal waste contract.
There is also thought to be opportunity on the River Lee to transport recyclables.
11 British Waterways indicated that a typical section of canal, without locks, is capable of carrying around 2,500
tonnes per day of waste.
39

4.101. One other potential major initiative at present in London is a proposal at Old Oak
Sidings, at Willesden. This site has good rail and canal access and would make an ideal
portal for an inter-modal waste transfer station. The main incentive for this project is
the contract for the Cross London Rail Link within which the canal could be used for
bringing in aggregate and taking out spoil and other wastes. Also, central to this
project is a recycling station at the same location to recycle a range of materials,
especially aggregates. British Waterways indicated that this could take 45,000 lorry
movements off the roads over a seven year period. British Waterways are going to
commission a project in the near future to look at the potential for wastes and other
freight to be moved along a 26 mile section of this canal from nearby businesses.
4.102. British Waterways also noted the potential for the transport of dry cargos of cardboard
due to the high price, providing they can access the mills. It appears that whilst this
may be possible via the River Thames, downstream transport is difficult, particularly in
the winter. This is due to the seaworthiness of the canal boats on the river and hence a
new generation of barges may be required to further develop such opportunities.
4.103. The major limitation in increasing canal transport is due to the lack of wharf sites; this is
aggravated by the fact that many have been developed for canal-side housing and other
development. British Waterways have just released a Best Practice Guide on Planning
for Freight on Inland Waterways. However, no special protection is given to canals for
freight transport, and particularly wastes, and the encouragement of waste transport by
canal is not particularly encouraged within current planning policy and guidance.
4.104. British Waterways informed us that there was some opposition to moving waste (and
freight) by canal in London. This came from two main groups; house owners with
canal-side properties who were objecting to visual impact, odour and noise, and also
from boaters, especially the live-aboards, who were also concerned about disturbance
from wash. Whilst such objections are understandable, it is recommended that the
benefits of water-borne transport for London as a whole is likely to outweigh the
impacts on individuals.
Recommendation 5: It is recommended that Transport for London should take the
lead in promoting the transport of waste by water wherever feasible, and to
lobby Government to support the use of the river and canal network for this
purpose.
Recommendation 6: In order to facilitate the transport of waste by water, it is
recommended that suitable sites in London are reserved for such use in Waste
Local Plans.
4.105. British Waterways work closely with the Port of London Authority and the Government.
The Government are keen to promote water-borne freight transport, as is demonstrated
by the Freight Facility Grants. However, the grant does not apply for water-borne
freight transport if there is no alternative to water (or rail) transport.
Recommendation 7: It is recommended that the GLA supports British Waterways in
their efforts to get Government to amend the regulations relating to the
receipt of Freight Facility Grants such that it should apply to transport by
water (and by rail) even where there is no alternative.
4.106. British Waterways commented that compulsion for projects to consider waste transport
at the ’front-end’ would be very helpful for them.
40

Recommendation 8: It is recommended that Government is lobbied to issue planning
guidance to encourage developers to consider the way in which waste
generated by their proposals is to be managed and transported, particularly by
water, at the outset of the planning and design process.
4.107. It is also understood that LondonWaste has considered using inland waterways to
transport their wastes in the future. They particularly mentioned the benefits of
reduced impacts on local road networks.
SME Activity
Context
4.108. Small and medium sized enterprises are extremely important to the UK, both in terms of
number of employees and turnover. SMEs, including the self-employed, accounted for
over 99% of the UK’s 3.8 million businesses at the start of 2002, as well as 56% of
employment (12.6 million people) and 52% of total UK turnover (£1,100 billion)
(source: SBS (Small Business Service) Statistics Team, SME Statistics for the UK). This
included 1.6 million (i.e. 69%) self employed 12 .
4.109. Data on the breakdown of London’s companies by size and sector was sourced from the
Small Business Service web-site for 2001 (which is the most recent data with a sectoral
split for London). This data has been compiled into two tables (percentages and
absolute numbers) which are presented in Appendix C. From these tables it can be
seen that in London, there were just under 673,000 SMEs in 2001, which represents
99.8% of all London businesses. In terms of employees (including the self-employed),
this was 43% of total workforce in London. And, in terms of turnover, this amounted to
49% (£1,924.79 million). Therefore, it can be seen that the vast majority of companies
in London are SMEs, and they account for just under half of the employment and
turnover.
4.110. It is useful to consider the different sizes of SMEs since there are considerable
differences between a one person company and that with 250 employees. We have split
SMEs into three size bands; i.e. micro companies with fewer than 10 employees
(including the self-employed), small companies (10-40 employees) and medium
companies (50-249 employees). From the tables in Appendix C, it can be seen that the
micro companies account for the greater proportion of all (i.e. including non-SME
companies) London’s companies (96%), with small and medium companies only a tiny
proportion (4% and 0.6% respectively). In terms of employment, the micro companies
are again dominant with 24% of all employment, with small and medium companies
comprising just under 10% each. In terms of turnover, the micro companies are again
the most dominant section of the SMEs with 19% of all companies, with the small and
medium companies both at just under 15%.
4.111. The tables in Appendix C also show the split of SMEs by sector in London. From these
it can be seen that the agricultural, forestry and fishing sector is, not surprisingly, by far
the smallest sector, with financial the highest, followed by services. Taking the
commercial sectors as a whole 13 , the SMEs comprise 46% by employment (of both SMEs
and non-SMEs), of which the micros account for 25% of all employment with an almost
even split of around 10% each for the small and medium. In the industrial sectors,
12 Self-employed is taken to include sole proprietorships, partnerships comprising only the self-employed ownermanager(s)
and companies comprising only an employee director.
13 i.e. wholesale, retail & repairs; hotels and restaurants; financial intermediation; real estate, renting and business
activities; health; education; other services.
41

SMEs comprise a slightly lower proportion (i.e. 20%) of all employment than in the
commercial sector, although this is much less in real terms (i.e. 258,000 compared to
800,000). Waste from micros is more than likely to be collected with municipal waste.
SME Survey
4.112. An interesting insight into the behaviour of SMEs with respect to the environment is
provided by the findings of the recent SME-nvironment 2003 survey of SMEs by
NetRegs. NetRegs is a web based resource designed to help SMEs access and
understand environmental legislation. It has been developed by the Environment
Agency, the Scottish Environmental Protection Agency, and the Environment and
Heritage Service (Northern Ireland), in conjunction with the DTIs Small Business Service.
4.113. This survey was carried out by W S Atkins. It included over 8,000 SMEs in 28 sectors. It
was conducted by telephone interview and nearly half those who responded were either
the owners or managing directors. It is not known how many of the companies
surveyed were in London. The survey tried to reflect the overall distribution of company
size in the way that it was structured, and responses were weighted to represent the size
(micro, small and medium companies) and sector distribution of UK SMEs within the 28
sectors. However, it is noted that relatively little attention was given to some of the
commercial sectors, other than hotels and restaurants and the retail of vehicles and
fuels.
Recommendation 9: It is recommended that, subject to the views of NetRegs, a more
detailed survey of waste management practice of commercial SMEs in London
be undertaken to augment the recent results of the SME-nvironment survey
2003 carried out by NetRegs.
4.114. The survey 14 found that only 23% of SMEs had introduced any practical measures to
limit their environmental impact, of which the highest response was to designate a
person to be responsible for environmental issues (48%), followed by putting in place a
programme of environmental improvements (35%). It is interesting to note that only
18% of construction businesses and 22% of textile companies had implemented any
kind of measures, despite their potential for relatively high environmental impacts.
Other key findings include:
• Only 24% of SMEs had an environmental policy (although this was 54% for medium
sized companies), of which the lowest sectors were textiles, leather, clothing,
construction, land transport, and printing and publishing;
• Only 3% of SMEs had a certified EMS, and only a further 1% had plans to introduce
one (the larger the business, the more likely they were to have introduced one) of
which the lowest scoring sectors were construction, land transport, and printing and
publishing;
• Only 18% of SMEs could name any environmental legislation, with again a better
performance from medium sized companies (25%) compared to small (23%) and
micro (17%), although 77% of all SMEs surveyed had heard of at least one piece of
legislation when prompted with a list;
• The key driver for promoting good environmental practice is the reduced risk of
prosecution (75%), followed by creating good relations with customers, reduced
operating costs, and improved competitiveness;
14 The full report is available on the NetRegs web-site (www.netregs.gov.uk).
42

• Of those companies who had taken some form of positive environmental action,
54% were motivated by concern for the environment, 39% by legislative pressure,
8% by potential business benefits and 4% by customer pressure
• SMEs are most likely to ask their local authority for assistance on environmental
matters (60% of those who had sought help), followed by waste businesses (35%),
the regulator (35%), trade/professional organisations (14%) and consultants (10%).
However, not all local authorities may be geared up for giving this kind of advice.
• 41% of SMEs would like more information and advice on environmental issues.
Recommendation 10: It is recommended that support is provided to local authorities
to advise SMEs about environmental (including waste-related) matters, as the
majority seek assistance from local authorities.
4.115. From the report, it appears that specific questions were not asked on the costs and
benefits of waste minimisation.
4.116. The findings of the survey suggest that the majority of SMEs have undertaken little
action to directly improve their impacts on the environment and have a poor knowledge
of regulatory issues although nearly half would like more information. Nevertheless,
they recognise the potential benefits of good environmental performance and,
interestingly, the greatest driver by far was general concern for the environment
followed by legislative pressure, with potential business benefits and customer pressure
being relatively insignificant.
Recommendation 11: It is recommended that an increase in funding is sought for the
Waste and Resources Action Programme (WRAP) to ensure that start-up
assistance is available to as many SME recycling and reprocessing businesses
as possible.
Recommendation 12: SME participation in recycling should be promoted through
measures that make it easy and cheap to participate. These should include the
targeting of clusters of neighbouring businesses, and further investigation of
mixed dry recyclables systems which avoid the need for complete source
separation by providing processing at a central separation facility.
Large Company Activity
4.117. The tables in Appendix C also provide data on the large (250-499 employees) and very
large companies (over 500 employees) in London. Whilst these account for a fraction of
the total number of companies in London, they provide 57% of total employment
(SMEs, large and very large companies) of which the vast majority (52% of total
employment) is in the very large companies. Once again, the commercial sector is
dominant with the greatest number of employees (circa 650,000) in each of the very
large companies of the wholesale, retail and hospitality and the financial and business
sectors. Transport, is the highest industrial sector (520,000 employees in very large
companies). Of this sector, there are 17,064 employees under the control of Transport
for London, which accounts for 3.28% of the total number of employees. Data was not
available for the construction and agricultural sectors in the large and very large
categories, and hence comparisons cannot be drawn in this regard.
43

Drivers for Sustainable Waste Management Practices
4.118. The following sections discuss drivers for sustainable waste management and aids to
best practice. The Copenhagen Waste Management System is a successful example of
achieving high recycling rates for C&I waste (see the information box below).
Copenhagen Waste Management System
In the early 1990s Copenhagen turned its waste management system around from a
landfill dominated disposal system to a position where recycling rates of over 50%
were being achieved with greatly reduced disposals to landfill. Denmark has a
national ban on combustible waste going to landfill, accepting that incineration with
energy recovery has a role to play in sustainable waste management. Denmark
adopted a National Waste Plan last year, which gives guidelines and objectives for all
the municipalities, and aims to reduce current levels of incineration by further
increasing recycling rates.
Commercial Waste Management
An important aspect of Danish waste regulation is that one single authority
(generally the municipality) has responsibility for both planning and implementation
of waste management, thus enabling an efficient system of treatment and
enforcement.
The first waste plan (1990) outlined a system for commercial waste, which specified
criteria for transport and treatment for each waste type, and introduced source
separation as a basic strategy. Waste operators and facilities that met the criteria
could then enter into a contract with the municipality and become a designated
facility in Copenhagen. The municipality has responsibility for all waste produced by
local businesses which are required to use the designated waste management
facilities. The system is based on the principle that the polluter pays: the waste
producer pays for the cost of collection and treatment directly to the contracted
collection company or treatment plant.
Waste producers, waste collectors and waste receiving enterprises must meet the
criteria of the waste plan, including reporting electronically to the municipality on
their activities, types and quantities of waste handled.
The change in commercial waste management was implemented without major
difficulties arising for the waste producers. Organisational rearrangements and
provision of extra storage space for waste containers was necessary. The extra costs
involved appeared to be covered by the savings on waste disposal achieved
(according to a survey in 1994 of the economic impact on 700 companies involved,
only 7% experienced cost increases.) As there is limited landfill capacity in Denmark
the disposal cost of using this route has historically been expensive. Landfill prices
in Denmark for 2002 were quoted in the UK Strategy Unit’s report 15 as
approximately £13-21/tonne, with a landfill tax of £28/tonne.
Success of the Copenhagen Waste Management System in reducing landfilling and
achieving high recycling rates, is attributed to:
• The municipal waste planning and regulation system.
15 Waste not, Want not. A strategy for tackling the waste problem in England. Strategy Unit, November 2002.
44

• The treatment facilities established as municipal partnerships.
• The national waste tax – all enterprises receiving waste for landfilling or
incineration must pay a tax for the waste received (no tax is required for
enterprises receiving waste for recycling.)
Sources: Pers. Comm. with Lene Bjerg Kristensen, Copenhagen Environmental Protection Agency
Commercial Sector
4.119. The burden of environmental legislation varies considerably according to both the size
of the enterprise and the sector in which it operates. There is relatively little
environmental legislation that impacts upon the service sector and, from a waste
perspective, the only pieces of legislation that could affect all organisations is the
Environmental Protection (Duty of Care Regulations) 1991, Producer Responsibility
Regulations, Waste Electrical and Electronic Equipment (WEEE) Directive, and the
Hazardous Waste Regulations. Nevertheless, the overwhelmingly majority of the smaller
service sector companies are likely to be largely unaffected by these regulations at a
practical level simply because their duty is being discharged through a Council operated
collection service, or because their landlord or waste management companies essentially
meet the legal obligation on their behalf (although they still retain a legal duty). SLR’s
experience in practice is that many SMEs, and particularly the smaller companies, are
very much unaware of these regulations.
4.120. The fact is that for the overwhelming majority of companies in the service sector there is
no legislative driver for them to reduce waste. Whilst there is, of course, an economic
driver, which is continuing to increase with rises in landfill tax, the evidence suggests
that this remains insignificant or, at the very least, unproven to SMEs in the commercial
sector (Brook Lyndhurst, Sustainable Business Development, Final Report for the
London Development Agency and Business Link for London, March 2004) (Envirowise,
pers. comm.). Further, whilst waste management costs are obviously of greater concern
for larger companies, there is again little evidence that such companies in the
commercial sector are as convinced by waste management considerations as a means of
reducing costs as other means. In short, the contribution that waste management costs
make to the office based sectors are relatively insignificant and hence this is a less
important - if not insignificant - driver for action.
4.121. The costs of waste management in other commercial sectors such as hospitality, retail,
wholesale, and education are likely to be higher. These sectors are also likely to have a
more diverse range of waste management requirements. However, the Brook Lyndhurst
report (Brook Lyndhurst 2004) again did not indicate that costs were a driver in the
restaurants that they were included in their survey (the wider hospitality sector, retail
and wholesale were not included in their project). It is noted that the costs of disposing
of white goods and, in particular, fridges is an increasing driver due to the EU Directive
on substances that deplete the ozone layer 16 .
4.122. It appears that perhaps the main driver at present for the smaller and medium sized
enterprises to adopt sustainable waste management practices is personal interest,
followed by reputation (Brook Lyndhurst 2004; SME-nvironment 2003). However, it is
interesting to note that Brook Lyndhurst also found that regulation can be a significant
driver.
16 Regulation (EC) No. 2037/2000 of the European Parliament and of the Council of 29 th June 2000 on
substances that deplete the ozone layer.
45

4.123. Whilst sustainable waste management practices are not part of the legislation package
that affects many commercial companies, the reuse of materials to avoid waste, along
with waste minimisation and recycling are now well enshrined in best practice and
Government policy. However, two recent surveys (Brook Lyndhurst 2004; SMEnvironment
2003) indicate that the majority of SMEs do not know where to turn for
advice and assistance on environmental issues. Brook Lyndhurst also suggests that even
with available information, SMEs may well be reluctant to address environmental issues
due to commercial or other pressures.
4.124. Larger commercial enterprises are perhaps better placed to implement waste
management practices than SMEs as many will have appointed a designated person to
handle environmental issues. In our experience, the main drivers for large companies
are perhaps reputation and public relations. Also, we have noted that an enthusiastic
person(s) with appropriate influence can have a significant affect on the internal
environmental culture of an organisation through championing sustainable approaches
to work. Whilst potential cost savings are obviously higher than for SMEs, they may well
not be highly significant when compared to other potential forms of cost saving for
office based sectors. This may be especially so in certain professions such as the
financial sector where salaries, rent and transport are likely to be far higher costs in
comparison to waste management, and hence perhaps the first area to consider when
costs savings are required. This should be part of good practice management. For
retail, wholesale, education and hospitality, however, it is envisaged that costs would be
an increasingly important driver but, again, perhaps not of immense significance.
Industrial Sector
4.125. The industrial sector SMEs have a much wider range of applicable legislation. Of
particular interest is the Packaging Waste Regulations 17 since this includes a requirement
to recover and recycle wastes. However, this does not apply to smaller companies (i.e.
those whose turnover is below £1m per annum and who handle less than 50 tonnes of
packaging per year). However, the practical impact of these regulations has arguably
been limited in some cases by companies who discharge their liabilities through joining a
registered compliance scheme.
4.126. In practice, there is a far greater driver for industry than commerce to implement
sustainable waste management practices, not just from a legislative perspective, but in
many cases due to costs. In general, industry produces a greater amount of waste per
employee and has more diverse waste streams than the commercial sectors. Many
industrial sectors also produce special waste and will be hit to a far greater extent by the
forthcoming Hazardous Waste Regulations which are expected to significantly increase
costs for much of industry (see chapter on hazardous wastes). Industry is also faced by
the requirement for discharge consents which can have a bearing on the amount of
wastes that they produce.
4.127. Larger enterprises are subject to a considerable raft of legislation under the Pollution,
Prevention and Control Act 1999 (PPC) which implements the EU Directive on
Integrated Pollution Prevention and Control (96/61/EC) (IPPC). This is aimed at
preventing and controlling pollution from major industrial plants. This legislation is
being implemented over a number of years on a sector by sector basis.
4.128. The PPC regulations require that industrial processes are permitted by the Regulator. In
determining a permit, the Regulator will require that the operation is being operated in
17 Producer Responsibility Obligations (Packaging Waste) Regulations 1997 as amended.
46

accordance with Best Available Techniques (BAT). The European Commission is
producing a set of BAT Reference Documents (BREF Notes), of which a number have
been produced to date. The Environment Agency is also producing additional guidance.
Assistance and aids to best practice
4.129. The above section has identified incentives for enterprises to go beyond legislative
compliance. The purpose of this section is to consider the aids available to promote
best practice on waste management and to examine the wider assistance available to
the waste recycling and materials reprocessing sectors. Much of this assistance is
currently targeted at C&I waste generators, so it is discussed in this Chapter, but where
there are links to C&D and hazardous waste these are noted.
4.130. Current and potential activities by publicly funded bodies operating in London other
than the GLA are considered in relation to the waste life cycle, from waste minimisation
and recycling by waste generators through to product development and market
stimulation. Table 4.9 summarises the life cycle stages at which interventions currently
take place. The activities of private sector providers of advice and other services, such
as consultants assisting businesses to develop an EMS, are not included in the table but
are discussed at the end of the section.
Table 4.9: Summary of waste life cycle stages at which national and local
bodies promote sustainable waste management
Bodies with direct
involvement
Minimisation
and recycling
by generators
Collection and
transport
Reprocessing Product
development
and market
stimulation
WRAP √ √ √ √
Envirowise √
Waste Watch 18 √
Business Link √
Environment Agency √
LWA √ √
London Remade √ √ √ √
WCAs √ √
Bodies with
supporting roles
LDA Integration of sustainable waste management within economic
planning, funds London Remade and other initiatives, dialogue
with other bodies, partner in LWA. LDA assisted GLA in
development of London Plan.
London First Integration of sustainable waste management within business
activities, partner in LWA, dialogue with members and other
bodies
18 Including Wastebusters
47

Encouragement of waste minimisation and recycling by generators
4.131. Envirowise and Waste Watch/Wastebusters promote waste minimisation and recycling in
London and elsewhere through activities such as one-to-one advisory services, waste
minimisation clubs, events of general relevance or targeted at specific business sectors,
and the provision of information resources. These organisations have relatively limited
resources in relation to the potential number of clients, which includes every business
and public sector organisation in London, subject to Envirowise’s inability under EU
state aid rules to assist public organisations. Nevertheless, they have been successful to
the extent their resources allow. In the period from 1998 to 2003 Waste Watch
Business Network helped over 600 businesses across London to save £430,824 and
divert 1,750 tonnes from landfill/incineration. 19 Further discussion of Envirowise’s
experience is included below.
4.132. The London Environment Centre (LEC), part of London Metropolitan University,
operates an SME environmental advice project called Environmental Business Action.
Funded from the Single Regeneration Budget since 2001, the project promotes
environmental best practice for SME's in LB Barking & Dagenham, LB Havering and
Thurrock. To date, about 30 companies have received assistance.
4.133. Another LEC project, 1-2-3 Business Environmental Efficiency, provided free
environmental support to almost 300 Small to Medium Sized Enterprises within the
'Objective 2 area' of East London. The project was funded in 2002 and 2003 by the
ERDF (European Regional Development Fund) but is now ended. It is likely that there
are and will continue to be similar local environmental advice projects funded from a
range of sources.
4.134. LEC with Business Link for London also operate Green Mark, an environmental branding
scheme for businesses developed through the 123 Business Environmental Efficiency
Project. The award scheme has 3 stages, with companies progressing through the
stages over a period of time, and is an introduction to the principles of environmental
management although it could ultimately lead to development of a full EMS. From the
launch date of Green Mark in July 2003 to November 2003, 24 companies were
awarded Green Mark Level One. 20 It would be useful for the GLA to further explore the
options for aligning and perhaps ultimately merging Green Mark with the Mayor’s Green
Procurement Code, to provide greater focus of resources and greater clarity for
business.
4.135. Waste minimisation clubs are often operated by partnerships of organisations. The
Envirowise website indicates that there are 11 located in London, although four of these
clubs are not currently active (South Thames Waste Alert, Harrow Waste Alert, Merton,
Bromley & Bexley Waste Alert) and there may be others not recorded. Their benefits
include a shared approach to learning and problem solving, and low cost access to
advice. Annual membership of the Waste Watch Business Network costs between
£23.50 (up to 10 employees) and £587.50 (more than 250 employees).
4.136. The LDA and Business Link for London have recently commissioned research on how to
improve the provision of environmental support services to SMEs in London. The first
stage was to identify the extent of such services in London 21 . The second stage
considers environmental support services from the business perspective and will
recommend how to achieve more effective provision of environmental support services
19 Source: Waste Watch website http://www.wastewatch.org.uk
20 Source: LEC website www.londonmet.ac.uk/lec
21 Mapping of sustainability advice provision in London. GEMS, LEC, CESMB and Wastebusters. June 2003.
48

in London. 22 The research included interviews with representatives from SMEs in four
target sectors – serviced offices, business services, catering, and printing and publishing.
Themes which emerged included the need to engage with businesses on their own
terms, provide sector-specific expert advice and continuity, and link environmental
advice provision with wider support initiatives.
4.137. London Remade provides educational resources and programmes associated with the
eco-sites it has assisted. To some extent these are targeted at businesses, particularly
businesses associated with recycling and reprocessing, although a major focus of most
activities is on the wider public such as schools and community groups.
4.138. Barriers to waste minimisation and recycling cited during consultations included
management time and effort required and the bundling of waste disposal costs with
other services (such as in serviced offices) removing the financial incentive to minimise
waste. These are particular issues for SMEs. Waste minimisations clubs can be
successful but receive minimal resources at present and may be best targeted at clusters
of similar businesses to ensure that the advice meets their specialist needs.
Recommendation 13: In order to provide further support and advice on sustainable
waste management for public sector and non-commercial organisations, it is
recommended that consideration should be given whether relevant information
and assistance could be provided by Government through or alongside
Envirowise.
4.139. Envirowise focuses its advice on waste minimisation as a way of increasing profit,
although there is also considerable reference to wider environmental issues. While it is
generally thought that Envirowise is targeted specifically at SMEs, it is actually aimed at
all business and many of the services can be accessed by companies of all sizes. This is
highlighted by the fact that on its Retail Therapy promotion, Envirowise is presenting
certificates for high achievement to companies that include Halfords, W H Smith, The
Body Shop, Boots, Manchester United, and Centre Parcs as well as smaller companies.
4.140. The services offered by Envirowise include:
• A wide range of publications on resource efficiency that are available free on-line
and in hard copy for all companies (over 350 publications have been published to
date);
• A wide range of events such as conferences and workshops on resource efficiency
that are free for any representatives of any organisation to attend (over 200 have
been run to date)
• Free advice of up to two hours for all organisations on the Environment and Energy
Helpline which is staffed by experts;
• Free “Fast Track” visit on waste issues to SMEs by independent experts (one visit of
up to 8 hours);
• Promotion of waste minimisation clubs
• Development and promotion of a range of tools, spreadsheets and presentations
available to all organisations to promote waste minimisation
4.141. As indicated above, Envirowise is aimed at business. Whilst any organisation can access
its web-site and download publications, the helpline and visits are for commercial
22 Sustainable Business Development. Final Report. Brook Lyndhurst. March 2004.
49

companies. There is no service offered to public sector and non-commercial
organisations. Whilst it is appreciated why Envirowise has been set up in this way, this
precludes assistance to sectors that can have significant waste management issues, such
as health, education and public administration. These sectors are expected to be of
greater significance in London than elsewhere in the UK. Whilst the health sector has
been active in promoting sustainable waste management (see later in this section).
4.142. Discussions with Envirowise indicate that it seeks to promote itself to business through
a number of ways, including:
• Funded programmes, such as Objective 2 areas;
• Business advisors at Business Link;
• Comments and editorials;
• 3 rd party business support organisations (e.g. Manufacturing Advisory Service); and,
• Trade associations.
4.143. Information is not collected on the nature of calls to the helpline or of company visits or
the size of the company. This would be useful to assist in assessing the success of the
programme and in planning future programmes.
Recommendation 14: In order to more effectively target potential users in the future,
it is recommended in relation to London in particular that information on the
size of companies contacting Envirowise, and the nature of their enquiries, is
compiled on a systematic basis.
4.144. We were informed that the future of the Envirowise programme is currently in doubt.
There is funding confirmed for up until 2007, but at present, there is some doubt as to
whether it will continue after this date. If this is the case, then there is expected that
there will be no further initiatives and, after this year, the service will start to be run
down. At this stage, it is understood that landfill tax is being considered as a future
source of funding, although no decision has been made on this issue.
4.145. It is recognised that Envirowise already has an infrastructure in place to provide advice
and support to companies of all sizes and across many sectors. Indeed, Envirowise
meets many if not all of the recommendations made in the Brook Lyndhurst report
(Brook Lyndhurst 2004) regarding the environmental support required for London’s
SMEs. Whilst it is recognised that Envirowise has not yet reached as many of London’s
companies as it would like, it is considered that it has the potential and experience to do
so and hence it would present a great loss and a missed opportunity if Envirowise was to
close.
Recommendation 15: It is recommended that Government is lobbied as a matter of
urgency to ensure the continued operation and expansion of Envirowise.
4.146. It is anticipated that London has a relatively high number of businesses in serviced
accommodation. Therefore, the waste producer is often not directly responsible for
waste management issues. This should be taken into account when developing waste
management programmes for the commercial sector in London.
4.147. Originally, the focus of Envirowise was very much on manufacturing. This reflected the
high proportion of industrial wastes in the country and the range of wastes as well. This
is particularly evident from the extensive range of Envirowise publications on
50

manufacturing. More recently, they have focused on retail, which included a drive on
greening the supply chain, and have also looked at serviced accommodation such as
business and retail parks. However, there has been little focus to date on offices in
particular, as well as other areas of commercial activity such as wholesale and
hospitality, although a number of their more general publications would have useful
advice and they have recently published a green office efficiency guide. It is also noted
that Friends of the Earth have published a green office handbook.
4.148. It is recognised that Envirowise does not meet the full requirements of London’s
commercial sectors. In particular, programmes for wholesale, hospitality and, in
particular, office based sectors (including serviced office accommodation) are required.
Recommendation 16: It is recommended that Government is lobbied to enable
Envirowise to extend its services simultaneously to all commercial businesses,
including wholesale, hospitality and, particularly, offices (including serviced
office accommodation).
Recommendation 17: As cost is not currently a particularly significant driver, and is
unlikely to be in the short term, for SMEs in adopting sustainable waste
management practices, it is recommended that the effectiveness of other
incentives be researched. This should include education and methods to raise
awareness of the environmental and social consequences of disposal-based
solutions.
4.149. Other mechanisms such as policy and enforcement are also considered necessary, as
discussed later in this chapter.
4.150. It is noted that there are a range of sources of advice which can make it difficult and
time consuming for organisations to know where to look for environmental information
and advice. This was identified in the Brook Lyndhurst report (Brook Lyndhurst 2004),
which calls for a single point of advice on environmental issues. This does not mean
that individual organisations should cease their environmental initiatives; indeed this
would be undesirable as it may well lead to a loss of individual expertise in specific
areas. However, a single authorative source of reference, advice and links would be very
welcome. This should also include a full list of publications to aid the dissemination of
research. It should include the full range of environmental issues and sectors
(commercial, industrial and public sector) across the national, European and
international spectrum.
Recommendation 18: It is recommended that a single point of advice on
environmental issues in London should be developed as a result of discussions
between the GLA, the London Development Agency, DEFRA, DTI Envirowise
and other relevant bodies.
4.151. It is interesting that the focus of Envirowise’s publications is on the business benefits
and particularly cost savings that can be achieved from improved environmental
performance whilst the SME-nvironment 2003 survey suggests that this is relatively low
down the list of reasons for improving environmental performance; the largest driver
being a general concern for the environment followed by legislative compliance. This
could be for a number of reasons which, as highlighted earlier by discussions with
Envirowise, could include the fact that cost savings from waste minimisation for many
small commercial companies are relatively insignificant. Alternatively, SMEs may simply
be unaware of the potential for cost savings. Alternatively, it may be that small
company entrepreneurs are more interested in the potential environmental impacts of
51

their companies than the larger companies, which are perhaps more affected by
shareholder demands.
4.152. The relationship between drivers for improved environmental performance and size of
company is a complex one, and the above survey is perhaps insufficient to allow firm
conclusions to be drawn. Nevertheless, it does appear that Envirowise’s focus on cost
reduction may be somewhat out of step with the apparent concern of SMEs for the
environment and legislative compliance.
4.153. The SME-nvironment 2003 survey also suggest that “greening the supply chain” is not
necessarily considered by SMEs (particularly micro and small companies) as an effective
approach to increasing environmental performance. Of course, this could be simply due
to the fact that pressure has not been put on them within their sectors, since this has
been a proven driver in certain lines of business and parts of the world, particularly
motor car manufacture and electronics. Recent work by Envirowise with major retailers
also highlights the benefits that can be accrued by focusing on waste minimisation
throughout the supply chain. SLRs experience does suggest that a “forced” approach
to environmental management through the supply chain can lead to enhanced
environmental performance, but it is also noted that measures forced on small
companies can be met by superficial and token gestures. For example, we have audited
companies with environmental policies and, perhaps, also procedures, but who have not
greatly increased environmental performance because there has not been a change of
culture; i.e. the policy has not been fully implemented.
Other Sources of Advice
4.154. In addition to the advice provided through voluntary programmes, regulators are also
approached for advice by businesses. During the course of other projects, we have
noted that the regulators are often criticised for failing to provide clear, consistent and,
on occasion, accurate advice. Whilst it is noted that the Environment Agency does
maintain a comprehensive set of guidance notes and provides legislative explanation on
its web-site, along with links to NetRegs, many organisations have found difficulty in
sourcing advice on specific issues. It has been suggested that this is because the people
dealing with telephone enquiries are often junior and inexperienced staff who do not
fully understand the regulations and guidance.
4.155. We have only encountered one such comment during the course of this project,
although the consultee concerned considered that this had been a common occurrence
that had caused frustration and considerable lost time.
4.156. The roles of the various bodies active in promoting sustainable waste management in
London could usefully be clarified in a document agreed by all participants and made
available through various means, including on the websites of the relevant bodies and
through trade associations.
Recommendation 19: It is recommended that discussions be held with the
Environment Agency with a view to improving access to clear, consistent and
accurate advice on waste matters. It is also recommended that a single portal
for environmental information of relevance to businesses is set up by
Government, along the lines of the Planning portal
(www.planningportal.gov.uk). Consideration should be given whether to
develop a single environmental, health and safety portal as these subjects are
often overseen by the same person or group within a business and the portal
site may therefore encourage greater awareness of the advice available.
52

4.157. The availability of multiple funding routes for environmental initiatives (including EU,
national Government, local authority, business associations, NGOs and universities) has
tended to lead to a fragmented series of initiatives addressing business waste
management and business environmental performance more generally.
Recommendation 20: It is recommended that encouragement should be given to
harmonise business waste management activities, and for future funding
support to be directed to this end. The aim should be for fewer, and properly
resourced initiatives with a wider out-reach promoting a consistent message.
Collection and transport systems
4.158. Consultations yielded relatively little evidence of intervention in improving collection,
transport and transfer systems for wider wastes, in contrast to the substantial funding
and advice through London Waste Action for improved collection systems for
household waste. For major waste generators such as the printing industry businesses
that supply Grosvenor Waste Management’s paper recycling plant (see below under
Reprocessing), collection systems are unlikely to be an obstacle. For SMEs which
generate relatively small volumes of various waste types, and sometimes have limited
storage available on site, the costs and effort associated with separating waste streams
for recycling can be a deterrent. Economies of scale such as the participation of clusters
of neighbouring businesses in a recycling service suggest a need for targeted recruiting
of businesses. Mixed dry recyclables systems, which avoid the need for source
separation by processing at a central separation facility, may also assist SMEs to
participate.
4.159. Collection and transport issues are a particular challenge for recyclable waste streams
that arise from a large number of dispersed SMEs, such as bottles and kitchen wastes
from restaurants and bars. Kitchen wastes present additional challenges including the
need to avoid contamination by other materials, the need for regular collections and
issues such as odour, flies and vermin. One positive feature of the licensed premises
sector is the presence of business chains and franchises which provide opportunities to
develop large collection contracts and deliver consistent training to staff and
standardised on-site facilities.
4.160. A recent initiative supported by WRAP in West Oxfordshire has trialled glass collection
from licensed premises in rural areas, investigating barriers and possible solutions (see
case study below). The trial ran from March 2002 to March 2004 and a report is
available 23 . The initiative has now been extended to other areas.
4.161. Westminster City Council has provided a mixed glass recycling collection from bars and
restaurants in the West End of London for at least 10 years. An officer at the
Westminster City Council commented that the scheme is currently ‘over-subscribed’ with
around 130 businesses participating, most of which are licensed premises.
4.162. The London Remade glass eco-site project has also worked to develop the glass
collection infrastructure in London. Berryman’s, the UK’s largest specialist glass
collection company, already collect a large volume of glass from licensed premises and
bottle banks in London and transport it to their Yorkshire plant for remanufacture of
bottles. Although this involves greater transport than reprocessing for local applications
23 Glass Goes Green – A Project to Identify the Legal and Commercial Barriers to Glass Recycling in a
Representative Sample Of Licensed Premises Within The Geographical Region Of West Oxfordshire.
Centre for Environmental Studies, Oxford Brookes University, for WRAP. March 2004.
53

such as road construction, it closes the recycling loop and avoids transport of virgin
materials or bottles over similar or greater distances.
54

Case Study – Glass Goes Green
Commissioned to run from March 2002 to March 2004 by WRAP, Glass Goes Green, is a
research initiative undertaken by the Department of Hospitality, Leisure and Tourism
Management’s Centre for Environmental Studies at Oxford Brookes University. The
remit of the research was to identify the legal and commercial barriers to glass recycling
in a representative sample of licensed premises within West Oxfordshire. Although it
concentrates primarily on rural areas, a number of lessons learnt can be applied to urban
contexts.
The research involved a literature review of relevant legislation and literature,
consultation of licensed retail establishments (LREs) to determine the current recycling
status and to investigate attitudes towards recycling, and a glass audit to establish the
quantity and types of glass being disposed of. It generated numerous findings,
including:
• 600,000 tonnes (27%) of the 2.2 million tonnes of container glass waste discarded
in the area comes from the licensed retail trade.
• Despite the significant economic value of the glass discarded by these
establishments, only a small proportion of it is recycled (15 – 20%) with most of
the remainder being sent to landfill. Of the proportion that is recycled most is
generally not used for new containers but as aggregate.
• Recycling schemes are generally more commonly practised in urban areas due to
the associated cost benefits.
• Re-use of glass bottles by the drinks industry has reduced amongst those glass
producers and LREs surveyed, due to sorting and cleaning costs, difficulty of
cleaning to required standard, consumer acceptance, lack of storage space, extra
operational labour required (e.g. to sort and crate bottles, paperwork), and
dissatisfaction with collection systems.
• Increasing rates for glass collection by current commercial schemes is becoming
economically unviable and has resulted in a dramatic reduction in the number of
schemes operating.
The research drew a number of conclusions from these findings and produced guidance
to assist Local Authorities and LREs to evaluate the effectiveness of implementing a
glass recycling scheme. The principal outcomes were:
• Nine recommended options for Government:
o Review and revise the Duty of Care Regulations.
o Increase information to licensed retail businesses.
o Charge for waste by weight rather than by lift.
o Itemise the contribution to landfill tax on waste disposal bills.
o Adjust Best Value Performance Regimes so that they cover Municipal Waste
rather than just Household Waste.
o Provide standard service contracts for licensed retail establishments to use
when negotiating with glass recycling operators.
o Regulate against the landfilling of specified recyclable wastes including
glass.
o Increase landfill tax to £35 per tonne immediately.
o Introduce a variable charging system for local authority trade waste
collection services.
• Guidance, to be published later in 2004 or early 2005, to Local Authorities and
55

LREs wishing to model the viability of, or establish, a trade glass waste recycling
scheme. This guidance is supported by:
o A toolkit for local authorities to estimate the commercial viability of running
a glass recycling scheme, essentially a spreadsheet based on the weight of
glass collected per kilometre travelled.
o A toolkit for LREs to estimate the volume/weight of glass they might
produce.
As a result of the finding of this initial pilot, and the recent take over of and charging
for the Recycle More Glass scheme by Berryman, a number of subsequent projects have
been commissioned, testing the models developed in other parts of the UK:
Bristol – ETC Recycling are investigating the benefits and barriers to collection
from urban and suburban areas.
Westminster – This is a WRAP sponsored project being carried out by Oxford
Brookes University to assess the impact of on-site glass crushing and the
willingness to pay for collection. It is initially covering 100 licensed premises and
is likely to be piloted for a period of three months from July 2004, with a view to
rolling it out thereafter, depending on the results of the study.
Glasgow – Valpak are investigating the effectiveness of front-of-house glass
crushing equipment in nightclubs.
All of the projects are initially for three months, although the schemes in Westminster
and Glasgow will continue beyond the study period. The ultimate objective is that the
data gathered will be compounded into a data bank to aid commercial, NGO and local
authority collection schemes undertake economic modelling. This guidance should be
published March 2005.
4.163. Organic waste collection for recycling (mainly as compost, to date) appears to have
focused on municipal waste collections rather than specialist collections of food waste
by waste management companies. The Sainsbury’s 2003 Environment Report 24 states
that Sainsbury’s has been trialling composting of organic waste materials for seven
years. One of the schemes in east and southeast London is now cost effective and
commercial. This activity has been largely driven by the Landfill Directive targets for
reduction of biodegradable municipal waste entering landfills.
4.164. Grosvenor Waste Management use road transport to take mixed dry recyclables from
Western Riverside to their plant at Bexley, and are interested in extending this to other
sources of recyclables. They are proposing to use barge transport in the future.
4.165. Rail transport offers a cost effective means of transportation of wastes. Rail is suitable
for high volumes of all waste materials, including industrial and commercial wastes.
Trains have a larger capacity than road haulage vehicles and offer a more economical
mode of transporting over long distances.
4.166. Rail transfer operations typically utilise direct toploading of non-compacted waste,
loading of pre-compacted waste into intermodal containers, or placement of bales in
conventional boxcars. A single train can save up to 200 truck trips and in many
situations can move the waste at a lower cost per tonne per mile, with greater fuel
efficiency and lower overall air emissions.
24 Being greener, Environment Report. J Sainsbury plc. 2003.
56

4.167. Rail transport is dependent upon the availability of an adequate number of railcars and
containers in addition to the ability of the rail network to collect and move the waste in
a timely manner. Long delays before departure or on route can result in odour
problems.
4.168. The West London Waste Authority have successfully transported wastes by rail since
1977, and currently use this form of transport for up to 75% of the total wastes they
send for disposal. Wastes are transported from Hillingdon rail transfer station to the
Shanks landfill site at Calvert on a nightly basis. The North London Waste Authority
also receives a daily rail transport service from the transfer station at Hendon to
Stewartby landfill site, also operated by Shanks. This service, from Hendon to the
landfill site and back, removes 192 long-distance lorries from the roads each day, thus
reducing congestion and pollution from haulage vehicles. It is understood that similar
arrangements are about to commence in East London through a long-term waste
disposal contract with Shanks.
4.169. Barriers to collection and transport systems vary with the type of waste. For most C&I
wastes the need for engagement of businesses and their staff, source separation and
collections from many dispersed sites can deter provision and participation. For organic
wastes additional barriers include the need for source separation, hygiene control
mechanisms and frequent collections. For hazardous wastes additional safety and
environmental considerations apply to storage and transport.
Reprocessing
4.170. The reprocessing sector is dominated by large reprocessors receiving municipal materials
and waste materials from construction and manufacturing businesses. There is also
some SME involvement, which is being actively promoted by WRAP, the LDA and
London Remade. The Government’s Best Value targets are the main driver of the
supply of municipal recyclables (mostly household) and have led to establishment of
facilities largely dedicated to this purpose. These are also suitable for many C&I wastes
but at present the capacity does not exist to take large amounts of additional material.
The availability of long-term supply contracts from Waste Management Authorities
encourages the establishment of reprocessing facilities for the municipal waste stream.
By contrast, there is less certainty of supply for recyclables from businesses, who are
price-sensitive and generally unwilling to commit to the length of contract required to
cover investment cycles for reprocessing plants.
Recommendation 21: In order to help to overcome the critical shortfall in investment
in reprocessing facilities in London that results from the lack of certainty of
contracts for the supply of recyclable business waste (as distinct from the
availability of long-term MSW contracts), it is recommended that the GLA – in
conjunction with London ReMade and the LDA – should investigate ways of
encouraging large waste producers to enter into long-term recycling contracts,
for example as an extension of the Green Procurement Code, or by
underwriting supply contracts.
4.171. London Remade has assisted in the establishment of several eco-sites for materials
separation and/or reprocessing and product development Table 4.10). These have a
strong emphasis on educational facilities and programmes so that they stimulate wider
awareness of what is possible.
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Table 4.10: Eco-sites established with London Remade’s assistance
Materials stream Name, Location and Operator Capacity (tpa)
C&D reprocessing London Remade C&D Eco-Site
(Charlton, Greenwich)
Day Aggregates
300,000
Glass reprocessing London Remade Glass Eco-Site
(Charlton, Greenwich - co-located with C&D
site)
Day Aggregates
30,000
Mixed materials MRF - London Remade Paper Eco Site
400,000 (with plans to
paper, cardboard, (Crayford, Bexley)
increase
plastic bottles and GrosvenorWaste Management with other
capacity to
aluminium cans partners
550tpa by
2005)
Organic waste
composting
Cleanaway Organics Eco Industrial Site
(Rainham, Havering)
Cleanaway (at their landfill site)
35,000
4.172. The Day Aggregates site processes hard demolition materials such as concrete into
aggregates for re-use in construction. The glass plant processes glass into cullet, mainly
for use in road construction applications but also for specialist products such as tiles.
4.173. Grosvenor Waste’s mixed materials site takes dry recyclables from MSW collections
(about 75,000 tpa), mainly from the Western Riverside and East London Waste
Authorities at present, but including some commercial waste (about 25,000 tpa).
However, this may change when new MRFs are built, including one at Smugglers Way
for Western Riverside. London Remade assisted in the investment costs of the
separation facility, as well as the associated educational facilities. The recyclables are
separated for reprocessing at other sites, generally outside London. The facility is being
redeveloped to increase dry recyclable capacity to 150,000 tpa by 2005.
4.174. Most of the remaining site capacity (about 300,000 tpa) processes paper waste from the
printing industry and other businesses. The paper is sorted into various grades and
transported to a variety of regional, national and international reprocessors. The plant is
fully operational at its current capacity, however, a company representative indicated
that there is substantial capacity for expansion of the site to receive a range of other
recyclables from both large contracts and small businesses. The company is considering
the business case for various expansion options.
4.175. Both of these companies developed their operations as an integrated part of an existing
business, rather than as a stand-alone operation. Grosvenor Waste Management’s
mixed materials facility works well with the company’s existing paper recycling business
and Day Aggregates’ C&D recycling plant fits with its construction and haulage industry
background.
4.176. The Cleanaway organics site at Havering was used as a demonstration site for
composting and although London Remade’s involvement has now ended Cleanaway
continues to use the site for composting organic waste. While organic waste processing
in London has focused on composting, other options are available. In particular, biogas
production from kitchen wastes and other putrescibles is well established in Germany
and is highly relevant to commercial sector wastes such as restaurant waste. A biogas
plant operates at Hoslworthy in Devon, processing cow slurry and abattoir wastes to
generate electricity which is fed into the national grid and producing a fertiliser for use
on local farms. Substantial EU funding was required to make the plant viable.
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4.177. Although market saturation for the main products (biogas and heat) is unlikely to
present difficulties, this may become the case with large scale composting. There is
potential for development of eco-industrial sites if sufficient land is available for linked
industries or a if a plant can be situated near end users requiring gas or heat.
Alternatively electricity can be generated for sale, although this is generally less energy
efficient than direct use of the gas. Disadvantages of biogas facilities include high
establishment costs and potential issues of odours and health and safety.
Recommendation 22: It is recommended that the feasibility of establishing
medium/large scale biogas facilities for the processing of London’s commercial
organic waste should be investigated, including the feasibility of using the
biogas and heat from such facilities in co-located industrial sites.
4.178. London Remade has commissioned feasibility studies for further sites for materials such
as plastics and clinical waste, but any commitment to take these forward would depend
on the availability of funding. The LDA is still funding London Remade to directly assist
with site establishment and development, with the latter’s focus shifting towards
facilitation.
4.179. WRAP is also involved in assisting the establishment of reprocessing sites nationally,
working to overcome the barriers to business development in the sector. WRAP’s
Recycling Fund can provide venture capital (see below), as recycling is a relatively new
industry and traditional sources of business finance can be reluctant to invest in
relatively unproven technologies and markets. WRAP also can assist with business plan
development where there is a strong underlying business proposal, and with
underwriting of recycling equipment resale value through the eQuip Residual Value
Guarantee (RVG) scheme.
4.180. WRAP’s £5.5m Recycling Fund supports SME companies in:
• sorting, reprocessing or recycling of paper, glass, plastic, wood, aggregates or
compostable material (including packaging materials); or
• collection technology insofar as it is specifically designed to enhance the above; or
• the manufacture of products incorporating the above recycled materials.
4.181. The fund is expected to provide equity finance to between 10 and 15 early stage
recycling or waste management SMEs in the UK. Qualifying companies will be those
that can demonstrate an economically sustainable market for their products or materials
but face difficulty in raising commercial equity finance.
4.182. Other barriers to reprocessing include the availability of suitable sites, planning issues
and lack of long-term supply contracts for business waste. The possibility of
competitors (recycling or disposal) establishing nearby is a deterrent to investment in
reprocessing facilities.
4.183. Locally, the LDA is in the process of letting a contract for delivery of a Waste Sector
Business Support Programme, to build on London Remade’s work to date. The key
features of the service, targeted at SMEs, will be:
• Provision of support with marketing and business development.
• Continued support with accessing preferred supplier lists.
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• Support for the development and adaptation of operations, products, and processes
relating to recycling, waste minimisation, and reprocessing.
• Assistance with industry relevant training.
• Specific training on commercial awareness.
• Support with accessing finance.
• Signposting.
4.184. There is close liaison between WRAP and London Remade. WRAP address national
issues, while London Remade feed their local experience into WRAP. This promotes a
common national approach and messages to business, with local implementation by
locally based organisations such as London Remade.
4.185. To an extent, different organisations involved in promoting sustainable waste
management prioritise the various waste streams differently in terms of the need for
new recycling, reprocessing and marketing initiatives. WRAP and London Remade
prioritise high-volume or high environmental impact waste streams such as C&D,
organics and plastics, as identified in the Enviros report for London Remade, Developing
Markets for Recyclable Materials In London (2000). The LDA places a higher priority on
waste streams that will generate substantial employment such as WEEE and ELVs, as
identified in the Green Alchemy report (2003). Although this may be quite appropriate,
as London Remade is able to bid for funding from a range of sources, at present it is
largely funded through the LDA, and the GLA should ensure that mechanisms are
available to address all priority waste streams in London.
Recommendation 23: It is recommended that the prioritisation accorded by
organisations such as WRAP, the LDA and London Remade to particular waste
streams for recycling and reprocessing should be monitored to check whether
London’s waste management needs are properly represented. This information
should be used to inform the Wider Waste Strategy which should be clear
about the priority waste streams to be addressed in London, with reduction
and recycling targets set for each.
Product development and market stimulation
4.186. London Remade has assisted with product development at the various eco-sites it
helped to establish. This has included assistance with compost product development,
development of recycled aggregates from hard demolition materials and development of
alternative uses for glass.
4.187. WRAP has a national assistance programme for businesses wishing to develop new
products from recyclable materials. As well as direct assistance to individual businesses
through advice and competitive grants, as discussed above, WRAP has undertaken
substantial research into product development and market stimulation for specific waste
streams in collaboration with industry. Examples include standards and specifications
for products such as recycled aggregates and compost, in association with the British
Standards Institute, developing crushed glass as a water filter medium and investigating
product options from recycled plastics.
4.188. WRAP also has an online pricing database for recyclables, which assists material
suppliers such as Waste Management Authorities to ensure that they get a fair price for
their waste materials and therefore helps the market operate efficiently.
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4.189. The Mayor’s Green Procurement Code aims to close the loop by encouraging
organisations in the capital to buy products made from recycled materials. London
Remade administers the code, with 9 staff assigned to this area of work. They specialise
in sectors such as London Boroughs, schools and events, the SME sector and the retail
sector. The Code has 320 members to date, at four levels of commitment. Level A1
simply requires attendance at least one event and maintaining contact with London
Remade. Level B2, the highest level, requires providing information about purchasing
to London Remade, setting realistic targets for green purchasing and monitoring
progress towards the targets. London Remade provides tailored advice to Code
members on how they can source green products, and uses the information about
members’ requirements and product specifications to help suppliers to develop products
that meet those requirements.
4.190. A London Remade consultee noted that there has been an evolution of approach in the
Code work towards engaging with the purchase culture rather than just with the
environmental/sustainability culture. Most of the contacts in member organisations are
purchasing officers and the service must be oriented towards meeting their needs.
4.191. London Remade encourages existing members to move upwards through the levels.
Now that sign-up is high, it will prioritise working with existing members and sectors
(‘deepening’ the impact) to improve their commitment to green procurement and
closing the loop by encouraging them to recycle as well. Most new member growth
(‘widening’ the impact) is now organic through referrals or inquiries. London Remade’s
staff capacity has limited its ability to take on large numbers of new members but it has
recently won a tender from the LDA for further development of green procurement and
supply chain development in London. The project runs from 2004-07, with a two-year
extension clause to 2009 subject to performance, and will:
• work with London-based organisations to influence purchasing behaviour to
increase the purchase of recycled content products;
• encourage increased capacity of local manufacturers to incorporate recyclates as
feedstock ;
• meet the demand of identified business sectors that use significant amounts of
products that could incorporate recyclates.
4.192. London Remade is now working to develop sectoral and product priorities for this
expansion of its work.
Recommendation 24: Given the apparent success of the Mayor’s Green Procurement
Code, it is recommended that funding should be maintained subject to a series
good performance targets.
Environmental Management Systems
4.193. Environmental management systems (EMS) were developed in the late 1980s to bring
the management of environmental impacts into the central management of an
organisation. The drivers were largely recognition of the failure of end-of-pipe
solutions to deliver effective pollution control and the need for organisations to exceed
legislative compliance to address contemporary environmental issues. The chemical
industry was a particularly strong force in developing EMS.
4.194. Organisations may seek to develop their own EMS or to follow a recognised standard.
They may then also seek certification to this standard to demonstrate compliance. The
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two internationally recognised standards are ISO 14001, (ISO 14001: 1996,
Environmental Management Systems – specification with guidance for use.) which has
by far the largest following world-wide, and the European EMAS (Eco-Management and
Audit Scheme). The latter is a more robust standard in two main regards:
• EMAS requires legislative compliance, whilst ISO 14001 requires a commitment to
comply; and,
• EMAS requires a public statement of environmental performance, whilst ISO 14001
requires that the environmental policy be made available to any interested party on
request.
4.195. Whilst ISO 14001 in particular has seen a high rate of uptake since its launch in 1996,
there are less than 4,000 ISO 14001 and EMAS registered companies in the UK out of a
total of over one million businesses registered at company house (Institute of
Environmental Management and Assessment web-site (www.IEMA.net)). A total of 123
companies (or sites) are certified to ISO 14001 within London 25 . These are distributed
across 25 sectors. The highest number for an individual sector is 10 companies for
mining and quarrying. The three next highest sectors, with eight each, are construction,
wholesale/retail trade 26 , and transport, storage and communications.
4.196. Environmental management systems and the major accompanying standards have both
their critics and supporters. Supporters point to the plethora of literature demonstrating
how organisations have increased their environmental performance and in doing so
saved significant costs through the development and implementation of an EMS. Critics
note that a company can obtain certification with a lack lustre EMS that may have had
no demonstrable effect on environmental performance.
4.197. Whilst ISO 14001 has been criticised for being ill-prepared for small companies, the
standard itself does make it clear that the nature and scope of the EMS should be
applicable to the size and nature of the organisation; i.e. a smaller organisation would
be expected to have a less sophisticated EMS. At present, ISO 14001 and ISO 14004
(the accompanying guidance) (ISO 14004: 1996, Environmental Management Systems –
general guidelines on principles, systems and supporting techniques) are being reviewed
and new versions will be published later this year. One aim of this review is to help
make the standard easier to use by small companies through increased clarity and a
greater amount of advice which is particularly aimed at areas where small companies
have struggled in the past (ISO Management Systems – March-April 2002).
4.198. In some cases EMS can be usefully applied to SMEs, including micro companies.
However, there are many cases, if not the majority, where EMS and, in particular, ISO
14001 is inappropriate for smaller sized companies. This depends very much on the
nature of the company and its potential environmental impacts.
4.199. A well designed EMS that is appropriate for the scale and nature of the company should
not be a great burden for a small company. However, it is acknowledged that ISO
14001 is not ideal for many SMEs. A less demanding system was launched in April 2003
through a new British Standard, i.e. BS 8555 (BS 8555:2003: Environmental
Management Systems. Guide to the phased implementation of an environmental
management system including the use of environmental performance evaluation). This
standard is particularly aimed at SMEs and allows a phased approach to be adopted.
25 Obtained from searching the ISO 14001 database on the EMAS web-site (www.emas.org.uk)
26 Also including repairs to motor vehicles and household goods.
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4.200. The experience of SLR’s staff with EMS suggests that there is an element of truth in
both of these assertions. Nevertheless, our experience is largely positive as we have
witnessed many companies increasing their environmental performance over time. We
have also worked with companies of very different sizes, from the micro level to major
multinationals. Our feeling is that ISO 14001 can be successfully applied to a small or
micro company, although it must be acknowledged that this may result in a significant
drain on resources which can have more acute effects on a company of this size.
4.201. Our experience working with SMEs and EMS is that such companies are far more likely
to develop a user-friendly and appropriate system in an efficient way if they have
external support. The only exceptions have been when they already have
knowledgeable and experienced staff. We also know of well meaning support schemes
that have failed to provide useful assistance to SMEs, perhaps because of the materials
produced, the timing, or the personalities of the people involved.
4.202. However, the London Development Agency (LDA) has been working with Business Link,
the GLA, the Government Office for London (GoL) and other partners to improve
environmental management advice and support for SMEs in London. They have
undertaken research into current provision of environmental advice to SMEs and further
research to assess the business case for SMEs. The next steps will involve both a pan-
London co-ordination to improve the impact and organisation of environmental advice
provision, as well as a series of pilots to test the findings of their research, and to
endeavour to identify models for more effective delivery. It is proposed to commission a
delivery partner through competitive tender to provide a central co-ordination function,
which will be closely linked to the existing London Business Network. One of the
responsibilities of this function will be to support LDA/GLA in a feasibility study of an
awareness-raising campaign. The coordination function outlined above will work with
the LDA to invite proposals to deliver the pilots. This work covers all environmental
management, but waste management, recycling and green procurement will form an
important element.
Recommendation 25: It is recommended that the increased use of Environmental
Management Systems (EMS) should be promoted amongst London’s major
companies and organisations, for example through voluntary agreements with
appropriate trade groups. This should apply both to the commercial and the
industrial sectors and should be made into a statutory obligation for larger
companies.
4.203. It is considered unhelpful to make EMS a requirement for all organisations since there
are many SMEs for whom a formal EMS is entirely inappropriate. Concentration should
therefore be on promoting this to those organisations with the greatest potential
environmental impacts in London.
Recommendation 26: It should be recognised that the successful implementation of
EMS for smaller organisations is likely to require some form of support.
Collaboration with the LDA should continue into researching the promotion
and provision of environmental management advice and support. It is also
recommended that the Institute of Environmental Management and
Assessment (IEMA) should be consulted in this regard as they are actively
involved in promoting BS 8885. Consultations should also be undertaken with
Envirowise with regard to the applicability of their existing services and
whether they are able to provide additional support to promote EMS in
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London. A phased approach is recommended in which particular sizes of
organisations in particular sectors are targeted over forthcoming years.
Environmental Reporting
4.204. Corporate environmental reports have been increasing both in terms of popularity and
scope over recent years. It is now an expectation that most major companies will
produce such a report and also many of the leading companies have widened the scope
to include “triple bottom line” reporting which includes social and environmental issues
as well as economic data and hence is a full sustainability report.
4.205. Environmental or sustainability reporting by itself does not require an improvement in
environmental or sustainability performance. However, the very act of producing data
and information on environmental and social impacts obviously allows the full range of
stakeholders to scrutinise performance and benchmark against the industry.
4.206. The question is, of course, whether this is an effective mechanism to increase
environmental performance and particularly, in the context of this study, sustainable
waste management. DEFRA commissioned a survey on the costs and benefits of
environmental reporting in 2001 which was undertaken by Environ (Environ 2001,
Report on a Survey of Environmental Reporting Costs and Benefits, prepared for DEFRA
(formerly DETR)). The survey was sent to 109 companies, of which 38 were FTSE100
companies, a further 17 were FTSE 350 companies and the remaining 54 companies
were ‘other’ environmental reporters. A total of 47 completed replies were received,
giving a response rate of 43.1% which was split reasonably well across the three groups
of companies. .
4.207. The study found that the respondents had been reporting for an average of 4.8 years,
with the longest reporter for 12 years. The survey included a question on whether a
reduction in waste arisings had been identified as a result of environmental reporting,
with a score of 1 being a limited benefit, 2 being an important benefit, and 3 being of
major benefit. The average score across all the respondents was 1.57, suggesting that
on average some benefit in reducing waste as a result of environmental reporting had
been identified. These results are also presented by sector in Table 4.11 below.
Table 4.11: Benefits of Environmental Reporting (from Environ 2001)
Type of
Benefit
Decreased
Waste
Average Scores
All Sectors Utilities Sector Transport Sector Diverse Services
1.57 2.00 1.67 0.75
Note: a score of 1=limited benefit; 2=important benefit, and 3=major benefit.
4.208. Table 4.11 shows that the utilities sector gained the most with a score of 2.00 indicating
that on average the companies received an important benefit. Not surprisingly, the
‘diverse sectors’ scored comparatively low (but still identifying some benefit) which may
perhaps reflect that they probably produce less waste than the industrial sectors.
4.209. In comparison to the other environmental benefits that respondents were asked about
in the survey (i.e. decreased resource and water usage and reduced energy expenditure),
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the averaged scores for waste were higher for each of the above sectors with the
exception of reduced energy expenditure for the transport and diverse services sectors.
4.210. Interestingly, the highest scores on this part of the survey were given to the less
tangible business and personnel benefits that may be associated with environmental
reporting. These particularly included stronger internal commitment, better
environmental management, increased employee awareness, improvements in
reputation, provision of environmental information, and improved stakeholder dialogue.
These benefits associated with environmental reporting suggest that the necessary
emphasis on waste management issues in this report should not be taken out of context
when considering the wider environmental and social issues connected with responsible
corporate behaviour.
4.211. The survey also asked about the costs of producing an environmental report. This
included all of the potential costs such as internal staff, copyright, report design and
report verification etc. The range of costs was quite considerable, from just under
£6,000 to just over £906,000, with an average of £86,000. It was noted that the costs
experienced by those four companies who did not produce a hard copy of the report
were considerably lower.
4.212. Environmental reporting is frequently criticised for the potential to “greenwash”, i.e. to
publish misleading environmental information. Certainly, anecdotal experience indicates
that some environmental reports fail to produce information on one or more of their
company’s major potential impacts, or present data and information in a misleading
manner. Interestingly, the Environ survey assessed the quality of respondents reports in
their survey against the internationally renowned Global Reporting Initiative (GRI)
guidelines 27 which outline best practice in sustainability reporting, and found them to be
largely of a high quality.
4.213. Despite the availability of GRI and other guidelines in producing environmental and
sustainability reports, there is still no single model. And, notwithstanding the findings
of the Environ report, standards of reporting do vary. This makes it difficult to evaluate
the quality and scope of a report, especially for the lay person. The quality of an
environmental report can, however, be assured through a process of independent
external verification. This is widely considered to be good practice, although it is not
always undertaken by any means. The costs of external verification in the Environ
survey ranged from £1,000 to £100,000, with an average cost of £8,206.
Unfortunately, the report did not identify how many companies undertook external
verification.
4.214. The Environ report suggests that environmental reporting can and does lead to
improved waste management performance. In the experience of SLR’s staff of
undertaking external report verification, it is likely that this is not just the reporting
process itself but is perhaps more likely to have originated in the objective and target
setting mechanism of environmental management systems (see above).
4.215. Nevertheless, environmental reporting is welcomed as a means of encouraging
environmental improvements.
Recommendation 27: It is recommended that environmental reporting by London’s
major businesses and public sector organisations should be strongly
27 Sustainability Reporting Guidelines, GRI (Global Reporting Initiative), 2000. Note, since the Environ report was
prepared, an updated version of the GRI has been produced (2002).
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encouraged, and that guidance and/or best practice references should be
prepared, including the key performance indicators that companies should be
reporting on. This may usefully also encompass sector-wide reporting in
conjunction with trade associations, which should become statutory. The
promotion of a web-based approach, perhaps along the lines of
www.capitalwastefacts.com, may be an appropriate way of reporting headline
indicators.
4.216. It is noted that the London Stock Exchange is preparing to create a centralised database
on the social and environmental performance of companies
(www.ethicalperformance.com).
Recommendation 28: It is recommended that discussions be held with the Stock
Exchange to explore the possibilities of using their centralised database on the
social and environmental performance of companies as part of the Wider Waste
Strategy.
Further Analysis of C&I Compositional Data
4.217. With reference to the SWMAL report discussed earlier, it is evident that a large
proportion of the commercial and industrial waste stream was described as general
wastes. Further analysis of this waste stream was undertaken during the study using
the compositional data provided in the SWAP report to try and reduce these unknowns.
The detailed results of the analysis are presented in Appendix D, and summarised
below.
Commercial Wastes
4.218. Within the commercial sector, paper and cardboard are very large waste streams that
could be some 2.2 million tonnes/annum. This would account for over half of the
commercial waste stream in London and 30% of the total commercial and industrial
waste stream in London. Of this amount, over 80% is expected to be recyclable which
equates to some 1.8 million tonnes per annum. Nevertheless, this still leaves an
estimated 415,000 tonnes of non-recyclable paper and cardboard.
4.219. Putrescibles are the next most significant waste stream within the commercial sector,
accounting for an estimated 400,000 tonnes, of which nearly 300,000 tonnes are
potentially compostable. Glass is the next largest waste stream, with all but 2,500
tonnes of the estimated 372,000 tonnes total being recyclable, particularly given the
current demand for glass. Plastic wastes are also significant, but in this case, the
majority (222,000 tonnes) are thought to be non-recyclable compared to the 93,000
tonnes which is estimated as recyclable.
4.220. The remaining waste streams that were estimated in the tables in Appendix D for the
commercial sector are all significant, albeit much lower than those highlighted above,
since they are in the tens of thousand rather than hundreds of thousand tonnes.
Hence, whilst the metals, textiles and other wastes are all considered important, they are
of less importance than paper, cardboard, putrescibles, glass and plastic for these
sectors. However, it is likely that the SWAP survey failed to identify one-off waste
events due to the nature of the survey. These could be significant over the course of a
year, but may well not be identified in a survey that is only undertaken four times in a
year. This would include WEEE, including computers and associated equipment, white
goods, office and hotel furniture, demolition and construction waste. These waste
streams are identified in the Environment Agency’s Waste Benchmarking Tool and some
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of the figures suggest that they may be of importance, although the data is
insufficiently detailed to allow any useful estimates to be made.
4.221. Phone consultations were undertaken with a variety of trade and business associations
in the commercial sector to try and define the some of the wastes classified as ‘general’
in other sources of information, and to obtain information about their views on waste
management and recycling which included the British Retail Consortium (BRC) and
British Hospitality Association (BHA). Neither of these organisations had or knew of
any waste studies relating to their particular sector and there were no plans to carry out
such studies.
Recommendation 29: It is recommended that discussions are held with relevant trade
associations to see to what extent their company members can be encouraged
to adopt sustainable waste management practices. It is suggested that contact
is made with London Remade to establish what means they have adopted to
recruit companies onto their Green Procurement Code. The next stage will
then be to contact the Trade Association Forum in order to determine a phased
strategy of initiating contact with trade associations directly. This could be
based on SIC codes.
4.222. Due to the difficulties of obtaining useful and up to date information, it should be
considered whether additional compositional surveys would provide useful information
to help develop a strategy. There is a danger that additional surveys would just provide
more numbers with a similar level of uncertainty.
Recommendation 30: It is recommended that a targeted programme of compositional
waste surveys should be carried out in those commercial sectors in London
where least information is available, particularly the wholesale and education
sectors. The aim of these surveys is to update and expand the ‘City of
Westminster Waste Analysis’ SWAP report of April 2001 such that this type of
information is available across the whole of London.
4.223. Despite the potential inaccuracies with the methodology used for this further analysis, it
is considered that this approach has shed more light on the composition of the
commercial waste streams. At this stage, it is recommended that the above figures are
used to provide an indication of the possible composition of the commercial waste
stream, rather than just referring to the SWMAL. Overall, our estimations suggest that
some 75% (i.e. 2.6 million tonnes) of the commercial waste stream is likely to be
potentially recyclable. Of the potential recyclables, 50% is estimated to be paper (1.3
million tonnes) and 20% cardboard (530,000 tonnes), 14% glass (370,000 tonnes), 11%
putrescible (284,000 tonnes) and 4% plastic (93,000 tonnes). It should be noted that
by far the largest proportion of plastic wastes are considered to be non-recyclable
(222,000 tonnes).
4.224. It has to be remembered that the above data is based on the SWMAL which is now more
than five years old. The LDA report, (London Development Agency, November 2003,
‘Understanding London’s Sectors’), forecast growth in terms of employee numbers for
the commercial sectors within London of 7%. It is difficult to predict the changes in
waste with regard to changes in employee numbers with a high degree of confidence,
due to differences in waste management practices within organisations, and hence this
has not been undertaken as part of this report. Instead, it is recommended to wait for
the completion of the Environment Agency’s waste production survey which is currently
being undertaken. Nevertheless, for the commercial sector, it is likely that the increased
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number of employees of perhaps some 7% will lead to an increase in waste arisings.
Given that wastes in the commercial sector are much more related to individuals than in
the industrial sector (where the more significant waste arisings are process dependent),
it may well be that the above waste streams could have risen by a similar amount to the
increased employee number (i.e. 7%). This would obviously be off-set by any
reductions in waste arisings due to waste minimisation and good practice. However, at
this stage, it is recommended that the above figures are likely to be on the low side and
that they should anticipate higher totals from the commercial sectors.
Recommendation 31: In the interim, before the results of the Environment Agency’s
update of the Strategic Waste Management Assessment, London (SWMAL)
2000 report are available, it is recommended that a contingency of between 4-
10% is made in estimating the amount of waste generated by the C&I sector in
order to take account of the growth of 7% in employee numbers over the next
two years, as forecast by the London Development Agency. A range of 4-10%
is put forward to cater for uncertainty relating to the growth or decline of
industrial activity in London over this period.
Recommendation 32: It is recommended that a reduction in the use of paper,
cardboard and plastics by the commercial sector is targeted as a priority in the
Wider Waste Strategy. Where paper, cardboard and plastics are used, they
should be recyclable and specific targets should be set as to the proportion
that should be recycled. The same approach should apply to the recycling of
glass, furniture, and waste electric and electrical equipment (WEEE).
Recommendation 33: In recognition that many of the improvements in waste
management have come about due to actions impacting on the supply chain, it
is recommended that consideration should be given to:
• compulsory EMS for certain members of particular trade associations;
• compulsory EMS for certain types of companies, including operators of
relatively large office facilities;
• development of a waste management charter which all organisations (above
a certain size) in London should be encouraged, or required to adhere to;
• restricting the use of disposable containers for serving food and drink
within all London eat-in establishments, and where they are used, for the
containers to be highly recoverable;
• lobby for imposing a significant fee for the use of plastic bags provided by
London businesses, or prohibiting the use of non-recyclable plastic bags;
• introducing measures to promote the development and use of highly
biodegradable plastic bags in London; and
• to promote the recycling of all plastic bags in London.
Industrial Wastes
4.225. It is hoped that the knowledge of the industrial sectors waste streams can be improved
in a similar way to the method used for the commercial sectors above. This is of
importance since, based on the SWAL data (included in the literature review earlier in
this chapter), half (49.7%)of the waste stream (1.36 million tonnes) is described as
‘general and biodegradable’. A further 5.6% (154,000 tonnes) is ‘contaminated
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general’. The largest waste streams with useful information are the ‘chemical and other’
at 400,000 tonnes (14.6%) and ‘paper and card’ at 378,000 tonnes (13.8). There is
also 174,000 tonnes of food waste (6.4%), 140,000 tonnes of metals and scrap
equipment (5.1%), 104,000 tonnes of inert and construction and demolition wastes
(3.5%), and 27,000 tonnes of mineral wastes and residues (1%).
4.226. Phone consultations were undertaken with a variety of trade and business associations
in the industrial sector to try and produce a better definition of some of the wastes
classified as ‘general’ in other sources of information, and to obtain information about
their views on waste management and recycling. This included the Food and Drink
Federation (FDA), British Printing Industries Federation (BPIF), Chilled Food Association
(CFA), Network Rail, the NHS Packaging and Supply Agency (PASA), the National
Health Service Estates (NHS) and the Chemical Industries Association (CIA). With the
exception of the NHS (see below), none were able to provide any information or knew
of any waste studies relating to their particular sector and there were no plans to carry
out such studies.
4.227. Reference was also made to the Environment Agency’s Waste Benchmarking Tool to see
if this could shed further light on the general section of the waste classification.
Unfortunately, the information provided by the tool did not allow a more detailed
analysis of the waste streams.
Recommendation 34: It is recommended that research is carried out into the
composition of waste in London that is currently described as ‘general’ with
the main focus being given to the following industries since they produce the
highest tonnages of waste in this category: food, drink and tobacco;
publishing, printing and recording; transport, storage, communications;
miscellaneous. Where relevant, consideration should be given to carrying out
this research in conjunction with trade associations with the aim of increasing
the participation of their members.
4.228. The NHS confirmed that healthcare waste services are procured at a local level rather
than nationally. The NHS Estates confirmed that they are addressing wastes in England
and have, for example, just produced a waste strategy that can be used by individual
Trusts based on the concept of total waste management. This will shortly be published
on their web-site. The representative that we spoke with was informed and
knowledgeable about waste issues and committed to moving away from landfill disposal
as a solution. She was pleased that the GLA were developing their strategy on wider
wastes, but was concerned in case this conflicted with the NHS waste strategy.
Recommendation 35: In developing the Wider Waste Strategy, it is recommended that
the GLA liaises with the National Health Service (NHS) to consider the
implications of the soon to be published NHS Waste Management Strategy. It
is also recommended that the NHS should be asked to provide data on the
composition of its wastes and what disposal routes are employed.
4.229. Individual Trusts complete annual returns on the EFIR (Estates and Facilities Information
Returns) system to NHS Estates on a wide range of data requirements. This includes
information on waste tonnages and costs for clinical, special and domestic wastes, along
with the total proportion and costs or recovered and recycled wastes. It is
commendable that this information is collected by the NHS.
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4.230. The NHS provided a detailed breakdown of the waste arisings from all the London
Strategic Health Authorities for 2002/3 from their EFIR data base for London. This is
summarised in Table 4.12.
Table 4.12: Waste Arisings and Disposal Costs for all London Strategic Health
Authorities 2002/3
Tonnes Cost (£)
Clinical Waste 75,493 9,396,000
Special Waste 6,002 303,080
Domestic Waste 164,145 4,379,503
Totals 245,640 14,078,583
4.231. From Table 4.12, it can be seen that just over £14 million was spent to dispose of nearly
a quarter of a million tonnes of waste for all the London Strategic Health Authorities in
2002/3. Two thirds of this was spent on clinical waste disposal, although this only
amounted to just under one third of the total. The largest proportion (69%) was for
domestic wastes which cost nearly £4.5 million to dispose of.
4.232. From the detailed data provided, the greatest single cost of waste disposal is for the
acute teaching hospitals (£4.2 million) which generate just under 22,000 tonnes/annum
across London. This is not surprising as they comprise the largest single type of hospital
(4,355 out of a total of 31,159 beds). This level of data and should allow waste
management resources to be aimed where they have the potential to provide the
greatest savings in terms of both tonnages and costs.
Recommendation 36: It is recommended that consideration should be given to
adopting a strategic approach to waste management across all London NHS
Trusts in order to make more efficient use of resources, and that the GLA
should discuss the potential for such an approach with NHS Estates.
4.233. The NHS representative explained that all Trusts should have a waste management
person, but that in the smaller Trusts this position may be combined with other
environmental issues such as energy, water, transport, etc. Hence, in the smaller Trusts,
it is possible that waste may be pushed down the agenda depending upon the priorities
and interests of the person looking after more than one area of interest. It was
confirmed that there are specialist waste management companies working with clinical
wastes.
4.234. In 2002 the NHS set out a new environmental strategy for the Trusts. The NHS do not
collect central information on this, so it is difficult to measure what all the Trusts have
done, but anecdotal evidence suggests that some Trusts have found recycling to be a
more costly option. This then presents a conflict since as a publicly funded organisation
the NHS has to strive for best value. In London, in particular, the storage of waste is an
issue due to the shortage of land, and this becomes more difficult with a requirement
for segregation as greater space is required. In summary, therefore, the two main
barriers to more sustainable waste management in the NHS are space and costs.
Recommendation 37: It is recommended that the NHS should be encouraged to make
it a requirement that all new buildings and refurbishment projects should
70

incorporate innovative waste transport mechanisms such as vacuum powered
chutes to minimise space requirements, and allow segregation at source.
These should include sufficient capacity for additional segregation in the
future, and ensure that clinical, non-clinical wastes, and special wastes are
handled in such a way as to prevent any risk of cross contamination.
Local Authority Collection and Disposal
Background
4.235. Local Authorities collect some 4.4 million tonnes of municipal wastes per annum in
London, of which approximately 1 million tonnes is non-household wastes. This
includes commercial wastes and industrial wastes.
4.236. The aim of this part of the study was to obtain further information on the nonhousehold
element of municipal solid wastes. The objectives were to consult with Local
Authorities to establish tonnages, management, customer range and, where possible,
future intentions with regard to the provision of this service.
4.237. Questionnaires were sent to all 37 of London’s waste collection authorities (WCAs),
waste disposal authorities (WDAs) and unitary authorities (UAs) asking about their
collection and disposal of commercial and industrial wastes. Responses were received
from 11 of the 21 WCAs, seven of the 12 UAs, and all of the four WDAs, which is a 60%
response rate. A detailed description of the questionnaire development, methodology
and analysis is presented in Appendix E. A summary of the main findings is set out
below.
Waste Collection and Disposal
4.238. The majority of authorities collect commercial and industrial wastes mixed with
household waste, with just a few collecting separately. Just over half of the
respondents collect industrial wastes. Only a minority collected commercial recyclables.
From the respondents, the collection services operated by the UAs were of a larger scale
than the WCAs and our data indicates that the greatest proportion of wastes are from
offices and retail, followed by hospitality, although there were some anomalies here with
one authority’s commercial wastes originating very largely from local authority and
government premises.
4.239. WCAs seem to favour direct service organisations (DSOs) for the collection of their
commercial and industrial wastes whilst WDAs and UAs favour private waste
management companies for their collection and disposal of commercial and industrial
wastes. All intended to continue using the same arrangement. With regard to contracts
with private companies, WCAs tended to have the shortest contracts with private
companies, WDAs the longest and UAs in-between.
4.240. With regard to collection, most respondents thought that their current arrangement was
the most beneficial way of providing a collection service. However, there were some
anomalies with regard to disposal with several respondents suggesting that their current
way of operating may not necessarily provide the most beneficial service in all regards.
Recommendation 38: It is recommended that consideration should be given in London
to the way in which data on commercial and industrial waste arisings and the
wastes handled – by customer type, customer size, and waste composition,
could be obtained on a regular basis.
71

4.241. For over half of the WCAs that responded, waste is transported using exclusively diesel
fuelled lorries. However, four authorities use alternative fuels to a differing degree
ranging from using exclusively LPG fuelled lorries, to 10% of wastes transported by a
combination of LPG and battery fuelled vehicles down to 5% of vehicles fuelled by LPG.
Recommendation 39: It is recommended that consideration should be given to what
extent the use of LPG and battery operated vehicles by waste collection
authorities would be beneficial, and how such a change could be implemented.
4.242. Only one authority (a UA) undertakes analysis of arisings by customer type and
composition at present. A further three authorities have the ability to undertake
analysis by customer type (one WCA and two UAs) and size (one WCA and two UAs)
and four (one WCA and three UAs) by composition, but they do not currently do so.
The majority could not provide this breakdown.
Recommendation 40: It is recommended that consideration should be given as to
whether certain types of service provision by waste collection authorities are
more advantageous than others, and, if so, how can additional support or
information be given to such authorities in this regard.
Future Trends
4.243. There were mixed responses on questions about future trends. Some authorities
expected an increase in total arisings, as well as increases in the proportion of
biodegradable matter in wastes, incineration and landfilling, while others thought it
would stay the same or, for incineration without energy recovery, that it would
decrease. The majority thought that recycling and composting would increase. Most
authorities thought it likely that they would meet their obligations under the Landfill
Directive.
4.244. Most thought that it was probably not possible for the authority to treat the majority of
their wastes within their own boundaries, whilst slightly more thought that this was
possible within Greater London. The authorities were split on whether appropriate
provision had been made within Local Plans for the future disposal of commercial and
industrial wastes that are under the control of the authority.
4.245. Only one new waste management facility had been constructed and become operational
since 1986 (with also one refurbished) in any of the local authority areas. Conversely, at
present, seventeen plants were proposed or under construction. The GLA should note
that there appears to have been a period when investment in new facilities in London
was minimal and that we now appear to be entering a stage when there are plans for a
much greater number of facilities.
Recommendation 41: It is recommended that the GLA in conjunction with all London
Boroughs should lobby Government to enable sufficient commercial waste
facilities to be provided to handle London’s wider wastes (for example by
adopting a similar approach to that of Copenhagen where the municipality has
responsibility for the management of all commercial waste, including C&D
waste, and sets criteria for the transport and treatment of each waste type;
only those facilities and operations that meet the criteria can enter into a
contract with the authorities to become designated waste management
facilities and operators).
72

Recommendation 42: In order to facilitate the provision of waste management
facilities to serve London’s needs, it is recommended that suitable sites for a
full range of facilities (ie. not just strategic facilities) are identified in Waste
Local Plans in the light of consultation with the Regional Technical Advisory
Board (RTAB).
4.246. With regard to environmental management systems, half of the respondents have or
intend to develop an EMS although only two have one in place at present. Slightly
more than half of the respondents have or intend to develop a quality management
system (QMS) in the future, whilst seven have some form of system in place or under
development at present (three of which are certified to ISO 9002).
Recommendation 43: It is recommended an assessment is made of whether the use of
environmental management systems (EMS) and quality management systems
(QMS) by local authorities is likely to bring benefits with regard to sustainable
waste management and, if so, to consider whether the provision of additional
support to the authorities would be useful in this regard.
73

5. Construction and Demolition Waste
Introduction
5.1. The aim of this part of the project was to evaluate the current management strategies
relating to construction and demolition wastes in London, building upon the existing
knowledge base, to enable and inform the development of appropriate policies within
the context of a wider waste strategy. The specific objectives listed in the project brief
are repeated below. A summary of the key findings from this chapter is presented in
Chapter 7.
Identify and engage with key stakeholders, to include:
Method
• Consultation with the major waste management companies offering services in relation
to construction and demolition waste in London, to establish collection and disposal
contracts in place, specifically in terms of tonnages and management.
• Consultation with the major construction and demolition companies operating in
London (and those due to start work on major development contracts), to establish
current or proposed management practices for waste.
• Assessment of the reuse and recycling options utilised to manage London’s
construction and demolition waste in terms of appropriateness, considering alternative
options specifically the potential for higher value usages.
• Consideration of the impact of planned development and redevelopment work across
London in terms of the quantity and composition of construction and demolition waste
requiring management.
• Assessment of the effectiveness to date, and potential applicability of specific
measures and instruments to promote waste minimisation, recycling and diversion from
landfill, to include:
- the current and potential role of waste exchanges in London and the potential
opportunities available through the promotion of industrial symbiosis;
- the role and impact of waste minimisation clubs in London;
- the use of environmental reporting;
- the use of standards;
- the impact of Unitary Development Plans.
5.2. Relevant literature on construction and demolition wastes in London was collected and
collated. A literature review was then undertaken to appraise existing information of
relevance to the study and identify concerns and gaps which need to be addressed to
meet the requirements of the brief. These gaps were then addressed through further
research and consultations with construction, demolition and waste management
companies, research organisations, local authorities and the Environment Agency.
5.3. The literature referred to and used in this study is listed below:
• Symonds Group and WRc, 2002 - Survey of Arisings and Use of Construction and
Demolition Waste: Main Document, ODPM.
• Reid, 2003 - A strategy for construction, demolition and excavation waste as
recycled aggregates, WRAP.
74

• Environment Agency, 2000 - Strategic Waste Management Assessment 2000:
London.
• Environment Agency, 2003 - SWaT 2002
• Environment Agency, 2001 - Strategic Waste Management Update 2001 28
• Best Foot Forward, 2002 - City Limits: A resource flow and ecological footprint for
Greater London.
• Sustainable Development UK, Quality of Life Counts: Indicators for a strategy for
sustainable development for the United Kingdom: 2004 Update. National Statistics
• London Development Agency, 2003 - Green alchemy turning green to gold:
Creating resource from London’s waste.
• Enviros, 2003 - Technical Assessment for Waste Management in London, Greater
London Authority.
• DTI, 2003 - Construction Annual Statistics 2003.
5.4. A list of the companies and organisations contacted for consultation are listed in
Appendix F.
Literature Review – Waste Arisings
The Symonds Group Surveys
5.5. The two Symonds Group reports are recognised as the main data sources on
construction and demolition wastes in England and Wales. They aim to capture data on
‘hard C&D waste’ and ‘excavation waste’ as defined in the following three categories:
i) Hard C&D waste: either segregated or mixed unprocessed/uncrushed materials
(particularly concrete, masonry, bricks, tiles, ‘blacktop’ etc.).
ii) Excavation waste: naturally occurring soil, stone, rock and similar materials
(whether clean or contaminated) which have been excavated as a result of site
preparation activities.
iii) Mixed hard C&D and excavation waste (mixed CDEW): a physical mixture of the
above.
5.6. Two surveys have been undertaken to date by the Symonds Group. The first was in
1999/2000 for the Minerals and Waste Planning Division of the DETR, with the support
of the National Assembly for Wales, which used data collected during 1999 and 2000,
whilst the second was for the Office of the Deputy Prime Minister (ODPM) in 2002 and
used data from 2001. The 2002 survey was carried out by sending out survey forms to
the receivers of hard wastes and excavation wastes arising from construction and
demolition sites across England and Wales. Survey forms were sent to:
• 632 operators of crushers and screens;
• the operators of 1,149 licensed landfills; and
• the operators of 539 registered exempt sites (paragraph 9 & 19 registered exempt
sites) 29 .
28 Available: http://www.environment-agency.gov.uk/subjects/waste/315439/170850/?version=1&lang=_e
75

5.7. The findings for England and Wales as a whole and London are presented in Table 5.1
below. The results were also reported by region.
Table 5.1: Estimated arisings of hard construction and demolition wastes and
excavation wastes (million tonnes) (from Symonds 2000 and 2002)
Data London England England and Wales
1999 6.60 69.19 72.50
2001 6.05 88.89 93.91
5.8. As previously mentioned, the data reported by Symonds is based on survey rather than
waste arisings data returns for the industry. Hence, the accuracy of the data is
dependent upon the survey response rate, the reliability of information provided by
respondents, and the methodology used by the researchers to extrapolate the results to
a national level and then to break it down breakdown again to the regional level. For
these reasons, the 2002 report acknowledges that the data are estimates only, and
states a confidence level of 90%. While Symonds also quote a similar degree of
confidence in the data accuracy at a national level (± 15%), the data for the London
region has a confidence level lying between an upper and lower band of ± 39%. It is
important to recognise that the survey results are data estimates only expressed as a
range. For example, the survey results indicate that hard C&D waste arisings in London
are likely to lie in the range between 3.7-8.4 million tonnes, with a mid-point of 6.05
million tonnes and a confidence level of 90%. These figures are presented in Table 5.2
below.
Table 5.2: Estimated arisings, confidence levels and limits of band for hard
construction and demolition wastes and excavation wastes (million tonnes)
(from Symonds 2002)
Estimated l Arisings
(mid-point
Band Width Lower end of band Upper end of
band
London 6.05 ± 39 3.70 8.40
England 88.89 ± 15 75.60 102.20
England & Wales 93.91 ± 15 79.80 108.00
5.9. Table 5.2 highlights that whilst there is a tendency to quote the total arisings of ‘hard’
and ‘excavated’ construction and demolition wastes in London as being 6.05 million
tonnes, in fact the survey results indicate that the ‘real’ figure is expected to lie within a
range of 3.7 to 8.4 million tonnes, with a confidence level of 90%. This suggests that it
is not prudent to assume that the real figure will necessarily lie close to the centre of
this range (i.e. 6.05 million tonnes), or indeed that it will definitely lie within this range
at all. The authors of the Symonds report also acknowledge the possibility of a bias
when coming down to the regional level due to sample size and local conditions which
may lead to greater inaccuracies at the regional level.
29 'Paragraph 9 sites' are registered exempt sites where exemption holders are permitted to spread up to
20,000m3/ha of soil, rock, ash, sludge, dredgings, or C&D waste for land reclamation purposes or agricultural
improvement. 'Paragraph 19 sites' are registered exempt sites where exemption holders are permitted to store or
use C&D waste, excavation waste, ash, clinker, rock, wood or gypsum in connection with recreational or
infrastructure projects, excluding land reclamation.
76

Recommendation 44: It is recommended that the GLA make it clear that the arisings
of ‘hard’ and excavated’ construction and demolition wastes in London may be
considerably different to the figure of 6.05 million tonnes that is often quoted
from the Symonds’ surveys of 2001 and 2002 and subsequently used as the
basis for further analysis. Such analyses should recognise that the Symonds’
survey data should be used as a range (3.70-8.40 million tonnes), with the
associated confidence level, and acknowledge the potential for significant
uncertainty in the modelling results. An appropriate contingency should be
included within any strategy measures based on the data modelling to allow
for a significantly greater, or indeed lesser, quantity.
5.10. In addition, the Symonds surveys exclude the other waste streams from construction
and demolition activity that do not fall under the category of ‘hard’ or ‘excavation’
wastes (refer definition in paragraph 5.5). These could be termed ‘soft’ C&D wastes and
include a wide range of wastes such as timber, plastics, metals, other packaging, plaster
and certain forms of hazardous wastes (excluding soils classified as ‘contaminated’
which are included under ‘excavation’ wastes). Discussions with the Environment
Agency confirmed that these ‘soft’ wastes are also not captured through their surveys
on commercial and industrial waste arisings. Therefore, these ‘soft’ wastes are
essentially a hidden waste stream since they are not included within either survey. This
is because the ‘soft’ construction and demolition wastes fall in-between the data
reported by DEFRA (formerly DETR)/ODPM and the Environment Agency as the former
surveys at the point of receipt for ‘hard’ and ‘excavation’ wastes whilst the latter surveys
at the point of arising (i.e. at commercial and industrial premises).
5.11. There is perhaps some ambiguity at present regarding whether these ‘soft’ wastes
should have been reported as a construction and demolition waste or classified as
industrial or perhaps commercial waste. Nevertheless, in the future, all wastes arising
from construction and demolition sites will need to be classified as ‘construction and
demolition waste’ with respect to the European Waste Catalogue (i.e. code 17 in the
catalogue) since this is a source based description. Therefore, with respect to the
definition in the European Waste Catalogue, it is apparent that the Symonds survey data
is likely to represent an underestimate of total construction and demolition wastes.
Since ‘soft’ C&D waste is excluded from any current surveys and very little composition
data is available on C&D wastes (refer to para. 5.17), it is not possible to predict the size
of this hidden waste stream with any confidence.
Recommendation 45: It should be made clear that ‘soft’ C&D wastes (eg. timber,
plastics, metals, packaging, plaster) are excluded from the Symonds’ survey
data estimates, and future planning / modelling should take steps to (a) allow
for this in any future waste modelling analyses, e.g. to inform the development
of the London Plan, and (b) obtain data on the size and composition of this
waste stream.
5.12. At present, a further Symonds study is underway, with publication anticipated in
September 2004 (funded by the Office of the Deputy Prime Minister). As part of this
study we contacted the authors, but unfortunately the current study is not sufficiently
advanced for them to be able to make any data available to us.
Strategic Waste Management Assessment: London
5.13. With regard to construction and demolition waste, the SWMA for London (SWMAL)
uses the data from Symonds as discussed above.
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City Limits
5.14. An alternative report on the waste arisings for London was undertaken by Best Foot
Forward Ltd. This was part of a wider study for developing an ‘ecological footprint’ for
London presented in a report entitled ‘City Limits’ in 2002. This study estimated that
waste arisings per annum from construction and demolition were 14.56 million tonnes,
which is considerably greater than the corresponding figure of 3.7 – 8.4 million tonnes
from the Symonds study. However the ecological footprint approach used by Best Foot
Forward is designed to quantify total resource flows for a given location, activity, event
or person using a life-cycle accounting methodology, rather than those which are
directly attributable to that activity. For example, an ecological footprint of a
construction site using this approach would be expected to include the waste generated
in the manufacturing of construction materials as well as that generated from the site
itself. Thus this approach would likely result in a higher estimate of the waste arisings
attributable to any given activity.
5.15. Discussions with the authors of the City Limits report about the basis for the higher
estimate of construction and demolition wastes, indicated some uncertainty about the
source and basis for the figure of 14.56 million tonnes quoted. The data source was
reported as an Enviros RIS Report titled ‘Managing London’s Waste’, commissioned by
London Waste Action and dating from February 2000. This in turn refers to another,
unreferenced source, dating from 1997. Hence the basis for the estimated 14.56 million
tonnes of C&D waste arisings is not clear and the figure is not considered to be reliable.
Literature Review - Waste Composition
5.16. Our literature search and consultations with relevant stakeholders indicated that only a
small number of C&D waste composition studies have been carried out in the UK to
date. The main ones are identified below:
• Hurley et al, 2001; comparison of construction and demolition wastes arisings (by
mass) from a number of individual projects
• APT Environmental, 2001; an assessment of construction waste composition, by
mass, of materials arriving at a waste transfer station in Nottingham.
• BRE have also undertaken compositional analysis of demolition and construction
wastes, this time by volume. This study is based on arisings from nine sites from
1999 to 2001and is based on a visual audit of skip wastes.
5.17. The Hurley and BRE studies report demolition and construction wastes separately,
although Hurley presents data by mass and BRE by volume. The APT study measured
construction and demolition waste combined. The results from the Hurley and APT
surveys are summarised in Table 5.3.
78

Table 5.3: Comparison of construction waste from individual projects (Hurley
et al., 2001), demolition waste (Hurley et al., 2001) and material arriving at
waste transfer station in Nottingham (APT Environmental, 2002)
Waste group
Range
(6 projects)
Construction waste Demolition waste Waste transfer
station
Avg. Avg. Avg.
% by mass % by mass % by mass % by mass
Timber 11 - 33 19.3 3.3 12.44
Concrete 0.5 - 18 5.9 40 13.72
Inert 1
Asphalt 0 3
0.5 - 27 11.1 24 40.85
Ceramic 3 - 11 3.0 0 2
Insulation 1 - 11 2.5 0 2
0 3
15 1.35
Plastic 4 - 37 13.0 1.90
Packaging 8 - 49 25.7 17
1.51
Metal 0.5 - 8 2.6
Plaster & cement 0.5 - 12 3.1 0 2
Miscellaneous 7 - 19 13.8 0.7 18.02
Total 100.00 100.00 99.50
Source: WRAP
Note: 1 Inert material includes bricks, masonry, rubble, hardcore, sand and stone
2 Included in figure for miscellaneous
3 Included in figure for inert
5.18. The BRE study was carried out by BRE staff at construction sites across England, using
the SMARTWaste tools to collect all relevant data. The results of the audits are shown
in Figures 5.1 and 5.2. The differences between the data presented were attributed by
BRE to the fact that all of the sites that were audited were at different stages of
building progress. The wastes change as the building work progresses, with wastes such
as packaging increasing as the build programme moves nearer to completion. Hence
Figures 5.1 and 5.2 represent construction waste data from different sites and at
different stages of project development. It should be noted that in both surveys, the
sample size of construction projects is very small (

Figure 5.1: Average total waste arisings by volume across 9 construction sites
audited from1999 to 2001 using SMARTWaste data (from BRE).
Source: BRE
13%
4%
5%
14%
5%
3%
0%
14%
7%
34%
1%
Packaging
Ceramics
Insulation
Plaster & cement
Inert
Metal
Plastic
Concrete
Timber
Miscellaneous
Furniture
Figure 5.2: Average volume of waste produced by a limited number of
construction sites between 1999-2001 (from BRE).
% of UK construction waste
Source : BRE
30.0
25.0
20.0
15.0
10.0
5.0
0.0
Timber
12.3
Concrete
10.2
Inert
7.1
Ceramic
8.6
Insulation
7.5
Plastic
3.2
Packaging
25.9
Metal
4.0
Plaster & Cement
11.5
Miscellaneous
5.19. With regard to demolition waste, both the Hurley and BRE studies cite ‘concrete’ as
the largest waste stream by mass and by volume (40% and 53% respectively). After
that, Hurley cites ‘inert’ as the second largest (24% by mass); this includes bricks,
masonry, rubble, hardcore, sand and stone, followed by plastic, packaging and metal
(17%) and asphalt (15%). In comparison, after concrete, BRE identified ceramics (23%
80
9.6

y volume) and furniture (17%) as the most significant arisings. This is due to the fact
that BRE carried out pre-demolition audits and therefore internal elements of the
buildings such as furniture were also included. The results of the BRE audit results are
presented in Table 5.4.
Table 5.4: % Composition of demolition waste by volume – SMARTWaste case
studies (from BRE).
Metal Plastic Concrete Timber Miscellaneous Ceramics Furniture Electrical
Goods
1.4 1.3 52.6 3.4 1.8 22.5 16.6 0.3
Source: BRE
5.20. With regard to construction wastes, the Hurley and BRE studies again report
separately by mass and volume. Both reports identify the largest waste stream as
packaging (26% and 34% respectively). There was then some similarity with Hurley
having timber at 19% (by mass) and BRE at 13% (by volume). Both have a
miscellaneous category of 14%, whilst Hurley has plastic at 13% and BRE at 5%, and
Hurley has plaster and cement at 3% whilst BRE has 14%. Hurley identifies inert at
11% (by mass) whilst BRE has it at 3% (by volume).
5.21. The results from these surveys suggest that there is a significant difference in the
composition between (a) demolition and construction wastes, particularly with regard to
the proportion of inert and non-inert wastes and (b) construction wastes depending on
the stage of the project development. The main difference between the construction
and demolition waste profiles is illustrated in Table 5.5 and suggests that a significant
difference exists between these two waste streams that are usually aggregated for data
recording and reporting purposes.
Table 5.5: Difference in the composition between demolition and construction
wastes with regard to inert and non-inert wastes
Demolition
Construction
Mass Study Volume Study
21% Non-Inert 24% Non-Inert
79% Inert 76% Inert
77% Non-Inert 78% Non-Inert
23% Inert 22% Inert
5.22. Generally the limited data available on construction and demolition waste composition
in the UK illustrates that whilst there is some level of commonality between the studies,
there are also some quite significant differences in the composition of arisings. This is
not surprising since the composition of materials arising from demolition and
construction activities varies according to the nature of the activity, building fabric, the
type of construction and the stage of the development programme. Furthermore, some
sites will require significant amounts of earthworks and may hence give rise to
excavation wastes which may be relatively small or non-existent on other sites. Finally,
of course, the above studies do not necessarily apply to London and hence it should not
be assumed that this composition can be simply applied to the total arisings to give a
breakdown into individual waste streams.
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5.23. The hazardous waste component of ‘construction and demolition waste (including
asbestos)’ comprised almost 73% of the hazardous waste arisings in the London region
in 2002 (Environment Agency, 2003). The hazardous waste component is thought to
come largely from contaminated soils, and asbestos, and more than 74% of this waste
type was produced in the three sub-regions of Western Riverside, South London and
South East London (Environment Agency, 2000). Hazardous waste is considered in
detail in Chapter 6 of this report.
5.24. It is reported (D. Knapman, Symonds) that robust data for C&D waste, including
composition data, exists for the Netherlands and Denmark, since these countries have
made historical efforts at measuring this. This data is available as part of a European DG
Environment Report ‘C&D Waste Management and their Economic Impacts (Feb 1999).
This data is already 5 years old but could form a useful comparison with the limited
available composition data from the UK.
5.25. The lack of robust reliable composition data for construction and demolition waste
arisings in the UK generally, and in London in particular, is apparent. This fact was
widely acknowledged during the consultations with stakeholders.
Recommendation 46: It is recommended that the lack of reliable composition data is
particularly taken into account in light of the level of uncertainty of the
Symonds survey data estimates for London. Consideration should be given to
commissioning a detailed survey of construction and demolition wastes in
London that would include (a) the separate measurement of wastes from
construction and demolition activities, and (b) detailed compositional analysis
of different types of construction project of relevance to London.
Literature Review – Treatment and Disposal
The Symonds Group Surveys
5.26. The Symonds reports also included data on the destination of construction and
demolition waste. Again, this applied only to the ‘hard’ and ‘excavated’ waste streams.
Table 5.6 presents the 2001 data for the treatment and disposal of ‘hard’ and
‘excavated’ construction and demolition waste for London, England, and England and
Wales. As previously highlighted in the arisings section, the figures provided in the
Symonds report are estimates based on survey responses rather than absolute figures.
For this reason, the figures are presented as upper and lower bands and a mid-point, for
each treatment and disposal route.
82

Table 5.6: Estimated range 30 of hard and excavated construction and
demolition waste in 2001 (million tonnes) subject to re-use, recycling, or
disposal (based on Symonds, 2002)
Used as recycled
aggregate
Used as recycled
soil
Used as
landfillengi
neering or
restoration
Used to backfill
quarry
voids
Spread on
registered
exempt
sites
Disposed of to
landfill
Upper 6.03 0.72 0.31 0.53 0.61 0.21 8.41
London Mid 4.34 0.52 0.22 0.38 0.44 0.15 6.05
Lower 2.65 0.31 0.13 0.23 0.27 0.10 3.69
Upper 41.94 7.83 10.06 12.18 25.76 4.45 102.22
England Mid 36.47 6.81 8.75 10.59 22.40 3.87 88.89
Lower 31.00 5.79 7.44 9.0 19.04 3.29 75.56
Upper 43.72 8.11 10.82 13.26 27.23 4.85 107.99
E & W Mid 38.02 7.05 9.41 11.53 23.68 4.22 93.91
Lower 32.32 5.99 8.0 9.80 20.13 3.59 79.83
5.27. Crushing ‘hard’ waste materials to secondary aggregates is the main form of recycling
for the demolition and construction industry. The proportion of C&D waste that is
reused (or recycled as soil following treatment) is considerably smaller. With regard to
the above figures, it is not recorded whether use as a recycled aggregate relates to high
or low grade aggregate, although the anecdotal evidence from the consultations
suggests that the majority of the aggregate is recycled as relatively low-grade
engineering fill, with increasing interest expressed by some C&D waste management
contractors in higher value recycling of aggregates for use as graded aggregate in road
construction material and for concrete production.
5.28. By way of illustration of the potential inaccuracies in the data estimates in Table 5.5, it
is apparent from the hazardous waste data in Chapter 6 that of the 458,300 tonnes of
hazardous wastes arisings in London in 2001, 73% (334,558 tonnes) were identified as
‘C&D Waste and Asbestos’ of which around 68% (227,500 tonnes) was identified as
contaminated soil and stones (EWC 170501). As contaminated material, the bulk of this
would have been landfilled; however the estimated quantity of C&D waste sent to
landfill (refer Table 5.5) is lower – in the estimated range of 100,000 – 210,000 tonnes.
There are a number of potential reasons for this difference; nevertheless it illustrates the
caution with which the data estimates from the construction and demolition waste
survey should be used.
30 The upper and lower end of the range has been calculated using the confidence level of ± 39% for London and ±
15% for England, and England and Wales from the figure quoted in the Symonds report, which is presented in this
table as the mid figure
83
Total

5.29. Nevertheless, the data estimates in Table 5.5 provide an insight into the fate of ‘hard’
and ‘excavation’ wastes arising from construction and demolition sites. Taking the ‘mid’
level from the above table, it can be seen that for London, the destinations for waste
arisings (by percentage by weight) are noticeably different from those for England in
the following respects:
• Disposal to landfill (2.5% in London compared to 4.4% in England).
• Landfill restoration and engineering (3.6% in London compared to 9.8% in
England).
• Backfill of quarry voids (6.3% in London compared to 11.9% in England).
• Spreading on registered exempt sites (7.3% in London compared to 25.2% in
England).
5.30. However, performance is similar for:
• Use as a recycled soil (8.6% in London compared to 7.7% in England).
5.31. Therefore it is apparent that London performs significantly better for:
• Use as a recycled aggregate (71.7% in London compared to 41% in England).
5.32. The Symonds study also identified the distance travelled from site to licensed landfill or
registered exempt site. The survey methodology asked respondents for an ‘estimate of
the maximum distance from which most C&D and soils travel to landfill’. The survey
results showed that very little ‘hard’ and ‘excavated’ construction and demolition waste
from London travelled more than 25 miles to a landfill or exempt site and only a small
proportion is hauled greater than 15 miles for recycling. With regard to the last bullet
point above, these transport statistics suggest that the majority (71.7%) of ‘recycled
aggregate’ is recycled and reused within London or within a radius of up to 25 miles.
Other Data Sources
5.33. It is possible that the relatively lower rate of landfilling of London’s construction and
demolition wastes in comparison with England and Wales as a whole is likely to be due
to its urban nature, i.e., the lack of landfills and quarries, farms, golf courses and other
land often used for the disposal of waste on registered exempt sites within a reasonable
proximity, in addition to the costs of transport. This same feature could help to explain
the relatively high use of recycled aggregates in London, i.e. the cost and limited
availability of bulk fill and virgin aggregate in London. The two factors combine to
result in a positive and valuable use of materials that in other circumstances would
perhaps be disposed of as waste.
5.34. There is a downward trend in the amount of construction and demolition waste going to
landfill, as measured by the Quality of Life Indicator. This is illustrated on a national
basis in Figure 5.3 below.
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Figure 5.3: Quality of Life 2004 Indicator: Construction and demolition waste
going to landfill
5.35. As part of this study we consulted with the National Federation of Demolition
Contractors. The Federation undertake an annual survey of their members to identify
the treatment and disposal route of hardcore from demolition projects. The Federation
provided us with the data from the most recent survey (2002/3). However, reliable data
could not be provided separately for London and so the data has not been used in this
study.
Literature Review – Treatment Facilities
5.36. The locations of licensed and registered exempt waste facilities treating construction
and demolition wastes were derived from consulting public records available from the
Environment Agency and the Greater London Authority. Further facilities that may treat
waste are, for example, mobile crushers, mobile screeners, and registered exempt sites.
There are 233 facilities for dealing with construction and demolition waste within
London plus a further 250 31 inert landfill sites outside of London. It is most likely there
are also other facilities located outside London that deal with London waste, for
example, mobile crushers. This situation is relatively dynamic. Details of the facilities in
London are presented in Table 5.7 below.
Table 5.7: Number of London based facilities treating construction and
demolition waste
Landfill Transfer
Station
MRF/C&D
Product
Exempt Para 9
& 19 Sites
Fixed Crusher
/ Screener
10 15 28 116 32 32
Mobile Crusher/
Screener
5.37. The above statistics for landfill and transfer stations are confirmed by the findings of the
Enviros (2003) report. However, the same report identifies a total of 174 facilities
(rather than 233) for recycling construction and demolition waste. The locations of the
facilities and, for some, the capacities, are also detailed within the Enviros (2003) report.
31 Located in the counties of Berkshire (14 sites), Buckinghamshire (16 sites), Cambridgeshire (28 sites), East
Sussex (8 sites), Essex (21 sites), Hampshire (29 sites), Hertfordshire (15 sites), Isle of Wight (9 sites), Kent (30
sites), Norfolk (24 sites), Northamptonshire (23 sites), Oxfordshire (2 sites), Suffolk (18 sites), Surrey (4 sites) and
West Sussex (10 sites).
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Consultations
5.38. Consultations were undertaken with approximately 50 organisations including
demolition, construction, waste management and recycling companies, trade
associations, research organisations and consultants, recycling organisations, and the
Environment Agency. The purpose was to try and address the uncertainties identified in
the literature review and build up a profile of the industry. The organisations were
selected by a variety of means, including suggestions by the trade associations and
other consultees, and our own knowledge of the industry. A full list of consultees is
included at Appendix F...
5.39. We have had responses from the majority of the consultees contacting during the
course of this study.
Consultations - Arisings
5.40. Very little additional quantitative data has been received from the consultations,
although most organisations noted that there was considerable potential for inaccuracy
with regard to the available published data.
Consultations - Treatment and Disposal
5.41. Our consultations indicate that contractors do not experience difficulties with finding
facilities (crushers, MRFs, transfer stations) in the London area for hard construction
and demolition wastes, but there was a shortage of facilities for dealing with specialist
wastes, for example, glass, tyres, reusable timber and plastics. One London MRF
operator described how their closest wood recycler was in Devon and the process so
critical that loads can be rejected at the gate and returned to London, all at the MRF
operator’s cost. Another waste management contractor who handles C&D wastes in
London signalled that the secondary materials markets were now sufficiently attractive
for them to look closely at ways of increasing recycling of all recyclable C&D materials,
primarily through transfer to reprocessing facilities outside of London.
5.42. Whilst consulting with contractors, the issue of the restricted number of landfills
accepting hazardous waste after July 2004 as a result of the Landfill Regulations was
raised. A review of the likely landfill capacity for hazardous wastes after co-disposal
ends in July 2004 is reported in Chapter 6. The general opinion of contractors on this
issue is that developers and regulators do not fully understand the time pressures
resulting from the closure of hazardous waste facilities from July 2004, and they also
feel that the traditional UK approach to many contaminated land remediations, i.e.
excavation and disposal of contaminated soils to landfill, will continue with the extra
transport costs passed onto the client. This is largely due to constraints on time, space
and cost of on-site remediation. They noted that familiarity with this approach helped
to reduce risk and uncertainty; also that it was faster to operate than the use of more
innovative techniques. This reduction in risk and operating time also had a positive
value in financial terms, by increasing certainty.
5.43. Most consultees considered that a possible impact of the Hazardous Waste Regulations,
at least in the short to medium term, may be to significantly hinder brownfield
development within London. This may be felt in terms of a reduction in site activity
and/or an increase in development costs. An increase in the movement of
contaminated soils by road, in terms of total distance, may also be anticipated. It is
recommended that the GLA considers the potential effect of this on house-building and
other construction projects within London.
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Recommendation 47: It is recommended that Government should be lobbied to
impose financial instruments and/or support other measures, such as
demonstration projects and dissemination of best practice, to promote the
treatment and reuse – rather than disposal – of contaminated soils from
demolition and construction sites.
5.44. Discussions with the consultees and a review of available statistics reveals that the
predominant approach by far for treating demolition wastes is by crushing for use on or
off site. It appears that whilst controlled de-construction is promoted as a sustainable
way of bringing down buildings, in as much as it allows for maximum reuse of materials,
deterrents to applying this best practice include:
• the developer’s programme (for example, the date of opening a unit);
• the critical path (for example, civil engineers needing to be on-site during
deconstruction);
• health and safety requirements; and,
• higher costs.
5.45. Conversely, one consultee informed us that de-construction as a technique had been
practised for many years and will continue to be used. Whilst de-construction rather
than demolition is not a new technique, the main influence over which technique to use
is health and safety rather than environmental considerations. De-construction is
usually related to high-rise buildings that cannot be demolished by traditional means
due to nearby residential or commercial premises.
5.46. We were also informed that developers very rarely adopt targets for reuse or recycling of
demolition materials and the main incentive was to get the development built and
operating as soon as possible. When targets were promoted, they were usually set by
public sector clients rather than the private sector. We were informed by one prominent
demolition company in London that whilst the public sector may push for an enhanced
environmental approach, there was a point at which developers would not be willing to
absorb additional costs (if these resulted) despite the environmental benefits. Hence,
there was a point at which economic considerations will take precedence over
environmental issues for developers across all sectors. It is apparent that the private
developer is rarely a driving force for sustainable waste management relating to
demolition and construction and that, whilst public sector contracts may encourage this
to a greater extent, only a relatively small additional price will be accepted before
market conditions apply.
5.47. Discussions with a number of waste contractors also indicated that the main driver for
sustainable waste management practices with regard to demolition and construction was
indeed costs rather than environmental issues. Many felt that they could achieve cost
savings in demolition through the recycling and reuse of hard materials which generated
cost savings over and above the landfill route. Contractors would usually identify such
savings at the tender stage and include them in their tender returns; hence the savings
are passed on to the client and in so doing a contractor that identifies the most
sustainable waste management practices may be more likely to win a project due to cost
reduction. Therefore, it can be seen that the increasing costs of landfill and scarcity of
sites in London is providing a real economic incentive for the recycling of all types of
construction and demolition wastes, including both ‘hard’ and ‘soft’ wastes. This
appears now to be a major stimulus for recycling these wastes, and is likely to continue
87

to be so in to the future. However many of the recycling and reprocessing facilities for
these ‘soft’ wastes are located outside of London.
5.48. Such cost advantages relate primarily to the recycling and reuse of bulk ‘hard’ and
‘excavation’ wastes (including soils) from construction and demolition sites, although
there is also anecdotal evidence that these considerations also apply to the recycling of
the ‘soft’ wastes. Whilst in certain circumstances specific other materials (such as fireplace
surrounds, timber panelling, internal doors, lighting and wiring etc) may have a resale
value, this is generally outweighed by the labour time required to dismantle and
remove such goods. Whilst they may be valuable within the context of certain types of
smaller project, they become increasingly insignificant on large-scale projects.
5.49. One prominent demolition contractor considered that further improvements in waste
management within the sector would only be driven through legislative changes,
perhaps accompanied by fiscal instruments (e.g. the Landfill Tax). The same consultee
also noted that the data being recorded by companies was insufficient to provide a
useful basis for assessing waste management practices within the sector, but that this
could not be expected to greatly improve without stricter requirements to improve
current data collection.
Recommendation 48: It is recommended that consideration should be given to the
opportunities that exist to improve the gathering of C&D waste management
data, including cooperation with trade associations and discussions with the
Environment Agency with regard to incorporation into licensing requirements.
Consultations – Tools to Aid Best Practice
5.50. Whilst the efficient use of resources has always been an issue for the construction and
demolition industry in financial and practicality terms, measures and initiatives to
improve the environmental performance were probably best defined in 1998 with the
publication of the Egan report ‘Rethinking Construction’, followed by ‘Building a Better
Quality of Life – A Strategy for More Sustainable Construction’ in 2000. A number of
related groups then started to develop key performance indicators for the industry and
in 2003 Construction Excellence was formed, which brought together the following
sustainable construction sector groups into one body:
• The Housing Forum.
• The Local Government Taskforce.
• Building Services Best Practice.
• The Infrastructure Task Force.
• M4I.
• The Quality Mark Scheme.
• IT Construction Best Practice.
5.51. A number of trade bodies and institutes have advisors or panels that focus on
environmental and sustainable construction issues, such as the Construction Federation,
Institute of Civil Engineers, and the Construction Industry Environmental Forum.
Further organisations apply research effort and consultancy services to improving and
implementing sustainable construction, such as CIRIA, BRE and BSRIA. WRAP, whose
focus is to create markets for sustainable waste management, also has a significant
involvement in the construction and demolition waste stream.
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5.52. A number of tools for assisting in the sourcing of facilities to handle construction and
demolition waste materials for reuse or recycling are also available. As part of this
project we have researched some of these tools and present a brief outline of the
provider and service offered in Table 5.8 below.
Table 5.8: Tools available to aid the reuse and recycling of construction and
demolition waste
Tool Summary of Tool
CIRIA Recycling
http://www.ciria.org.uk/recyc
ling
SalvoMie
www.salvomie.co.uk
BREMAP
http://www.bremap.co.uk
AggRegain
http://www.aggregain.co.uk
Web-site dedicated to locating construction recycling sites. The service
was funded by the RMC Environment Fund, ICE (Institute of Civil
Engineers), and DTI Partners in Innovation Scheme (Department of
Trade and Industry). Scotland, England and Wales are broken down into
11 regions (it is also possible to search by material), with the additional
ability to add your own site details. A search of the London Recycling
Sites gave 17 results. Each result links through to further information for
contacts and materials accepted/sold.
SalvoMIE is a materials information exchange for the construction and
landscaping business sectors in England and internationally. It was
started by BRE in 1999 funded by the DETR, and relaunched in October
2003 by the Salvo partnership, part funded by Biffa and ICE, and in
partnership with BREMAP which is a GIS system for finding waste
related UK businesses (see below). Browse by county for materials. Low
value waste materials, offered or wanted by the construction industry
and landscape professionals for re-use or recycling, can be posted on the
website. At the time of searching, 21 items were available nationwide
Database searchable by postcode or county which provides a map or list
of waste management facilities in that area. A search for facilities 7.5km
from Greater London gave 226 companies, which included local
authorities, metal recyclers and large waste management companies.
Telephone numbers, distances from postcode and links to further
company information (materials accepted, addresses) are also given.
The Aggregates Information Service was the predecessor to AggRegain.
AggRegain is a service from WRAP, funded through the Aggregates Levy
Sustainability. It has a link to a directory of more than 250 suppliers of
recycled and secondary aggregate products, at 350 locations throughout
England. A search can be conducted by name, town, postcode or by
region. The supplier database, which is part of the UK Recycled
Products Guide, is operated by Waste Watch, and is regularly up-dated.
A search for the London region was undertaken. 160 ‘results’ were
listed.
AggRegain also has the ‘AggRegain Specifier’. This tool helps specifiers
and buyers choose the right aggregate for the right application and then
download detailed technical notes, purchase orders and case studies.
The system can be navigated via:
• Project type, e.g. Road building and Housing development
• Application, e.g. Unbound sub-base, Bituminous bound
base course and Kerb haunching
• Product, e.g. Type 1 Granular sub-base material, Heavy
duty macadam, and Designated concrete GEN 0
• Material, This returns information related to aggregate
materials and tells you if and where they can be used in
any construction projects covered by the AggRegain site,
as well as providing additional information about the
materials themselves.
WRAP also have a similar RecycleWood website.
5.53. At the time of writing, Aggregain report around 250 registered members; these include
a wide range of C&D companies, including construction companies and material
specifiers. The AggRegain website is reportedly receiving around 1,000 hits per week to
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visit and review specific pages. A recent survey of the registered users was positive and
the website has been recently upgraded to include new EU standards and purchase
orders etc. AggRegain did also explain that the main function of their tool is as a
specifier, and to provide information on case studies, rather than to act as a trading
tool.
5.54. Whilst consulting with construction and demolition contractors, they were asked if they
use tools such as the ones detailed above. All demolition contractors confirmed that
they did not use any of the waste exchange and similar tools. Only one environmental
manager of a construction site responded positively when information on these websites
was distributed amongst sub-contractors. In at least some cases, it is anticipated that
the above sites are too much of a niche market (e.g. fireplaces, interior doors, etc.) or
too small in scale to be of interest to large demolition companies.
5.55. Many of the demolition contractors were also owners of their own treatment facilities
and they use their own facilities where this is practical and feasible in financial terms.
Larger demolition contractors also try and programme in works so that there is a degree
of synergy between sites, for example using the waste from one site on another, or they
transfer waste from a smaller site to be treated at a larger site. It was understood from
discussions that in situations where contractors work remotely from their home area, the
network of associates and contacts available through the supply-chain is used to
identify the locations of facilities. This informal network approach to identifying outlets
for reuse and recycling appears to work well. On the other hand, if there is a supply
problem, contractors will get in touch with the large waste management companies and
pay the premium associated with dealing with them. In summary, a good quantity
surveyor working for a construction and/or demolition contractor will be able to tap into
an extensive network of information and contacts within the industry, and this will be
translated through to winning jobs at the best price, partially based on locating the
destination and source of waste materials.
Recommendation 49: It is recommended that the promotion of waste exchanges for
C&D waste should not be a priority in London at this point in time.
5.56. New and emerging tools to assist best practice with regards to construction and
demolition waste are in the form of demolition audits. One such audit under
development is the Demolition Protocol, published for consultation in November 2003.
This project was funded in the first stage by ICE, London Remade and EnviroCentre, and
in the second stage by WRAP. Discussions with the author of this report revealed that
the protocol had been viewed positively following preliminary consultation, with the
London Borough of Brent having already adopted the Protocol. A consultation
document has been issued, following a re-drafting exercise, and is in the process of
informing the final policy. The demolition of Wembley Stadium is currently being used
as a showcase/case study event for the Demolition Protocol with more events planned
over the next one to two years to promote its adoption.
5.57. The Demolition Protocol has the key aim of encouraging the planning system at local
and national levels to require more efficient use of resources in relation to demolition
contracts and new builds. The Protocol is promoted as a resource efficiency model to
show how demolition materials can be considered as a high value material in new build.
It presents the components of Demolition Recovery Index (DRI) and New Build
Recovery Index (NBRI). The DRI describes potential efficiencies for materials recovery
from demolition while the NBRI covers the potential percentage and quantity of
recovered materials that could be specified in new build. These measures facilitate more
90

effective communication with planning authorities, including comparison to standards,
and allow for conditions to be placed on demolition and construction permissions.
5.58. Brent Council was identified as a Planning Authority that had taken on the protocol and
introduced it as part of Supplementary Planning Guidance 19 – Sustainable
Construction. For developments that exceed a defined threshold, matters covered by
SPG 19 are a material consideration in the planning process. London Borough of
Enfield and the City of Westminster also have sustainable construction polices (and
London Borough of Merton is in the process of developing such a policy) but the
adoption of the Demolition Protocol’s principles within these policies is unclear. As
outlined, at least three London boroughs have adopted some or all of the ICE
Demolition Protocol in the form of relevant planning policies or Supplementary Planning
Guidance. The GLA is also producing Supplementary Planning Guidance on sustainable
design.
5.59. The London Sustainable Construction Project is developing a Code of Practice that looks
at sustainable practices throughout the whole life cycle of construction, from initial
funding of the project through to final decommissioning. The Code is aimed at all the
people involved at every stage of the construction process, for example, funders,
designers, planners, contractors, etc. The Code will suggest performance specifications
and targets for good performance and will be backed up by an implementation guide.
The Demolition Protocol will form part of this best practice. The scoping stage of the
London Sustainable Construction Project has recently been completed and funders are
being sought for the next (development) stage.
Consultations – Attitudes to Best Practice
5.60. Whilst some contractors had a feeling they were doing all they could in terms of best
practice, others felt there was a need to educate consultants and developers more about
what is available and what is possible. One consultee said that the developer often
assumes that using waste materials can be risky in terms of quality and expense. The
consultee explained how these risks were often perceived rather than real, and whole
life costs for using recycled materials, including accounting for transport on and off site,
are frequently lower than landfilling and replacing with primary materials. Another
construction consultee described the differences in attitude between the older and
younger professionals in the industry, with the latter group being more likely to have
accepted that environmental issues are important considerations.
5.61. There was a constant reference to the terminology of waste licensing and how this
affects best practice. For example, one contractor described how his company
implemented best practice on site, by reusing, recycling and stockpiling materials for
later use on site. He then discovered that these practices were at odds with waste
management legislation and, having taken into account the costs associated with waste
management licensing, combined with his ‘close shave’ with the law, he has been put
off from trying to implement such practices again. Others suggested that any
association between construction and the use of ‘waste’ materials can put off potential
purchasers. Waste legislation (particularly waste management licensing requirements)
may be hindering sustainable waste management in demolition and construction,
especially with regard to the smaller operations.
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European Literature Review and Consultations – C&D waste
management lessons from other European Member States
5.62. Denmark, the Netherlands, Germany and Belgium are the leading European countries in
terms of percentage recycling of C&D waste 32 . They all have policy, legislative and other
measures in place which contribute to their achievement of high C&D recycling rates. A
summary of the measures used in these countries is set out in Appendix G.
Information has been gathered from a report by the Symonds Group Ltd (1999) 33
comparing C&D waste management measures across 15 European countries, a report by
the European Environment Agency (2002) 34 of waste minimisation practices in Europe,
and from information provided by a Policy Advisor for OVAM the Flemish Public Waste
Agency in Belgium. The policy, legislative and other measures used by these countries
include:
• Restrictions or bans on disposal of C&D waste in landfills.
• Taxes (landfill and other).
• Subsidies for recycling/re-use.
• Voluntary agreements between authorities, C&D industry and recycling
organisations.
• Research and development support.
• Pilot and demonstration projects.
• Education and training.
• Advisory services.
• Waste exchanges.
• Positive waste planning measures.
• Good monitoring systems of C&D waste production.
• Mandatory reporting systems.
• Standards, certification and quality assurance schemes.
Effectiveness of measures
5.63. In general, the Symonds Report found that no one measure can work in isolation, but
that C&D recycling rates of over 75% are only likely to be achieved if some form of ban
on landfilling C&D waste is imposed and enforced, or if a requirement is in place that all
C&D waste must be separated and each stream directed to some form of re-use or
recovery operation.
5.64. In addition, relying on landfill taxes or taxes on primary aggregates alone would not
achieve high recycling rates, especially in areas where engineers and demolition
contractors have easy access to landfills (or quarries), as the tax would have to be set at
politically unacceptable levels before behaviour would change.
32 Benchmarking of the Flemish Construction and Demolition Waste Policy Compared with Neighbouring Waste
Markets. BECO Group for OVAM (Flemish Waste Authority).
33 Construction and Demolition Waste Management Practices, and their Economic Impacts. Report to DGXI,
European Commission. Symonds Group Ltd in association with ARGUS, COWI and PRC Bouwcentrum, 1999.
34 Case studies on waste minimisation practices in Europe. European Environment Agency, 2002.
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5.65. Denmark, the Netherlands and Germany, are also among those countries that have done
most to require separation of C&D waste streams and to discourage inappropriate
landfilling. This has been achieved through regulations rather than landfill charges
alone, although their charges are generally higher than in other Member States.
5.66. The countries with high C&D recycling rates have run extensive research, pilot and
demonstration projects in the past. The Symonds Report suggests that the accumulated
experience is extensive and overlapping and should not be repeated, except for research
into:
• Selective demolition and processing of those construction materials that are
becoming widespread (e.g. glass and plastics).
• Designing for de-construction, and finding alternatives to construction materials and
techniques (e.g. use of bonding agents) which create problems at the point of
demolition where direct re-use is not an option.
5.67. Denmark, the Netherlands, Germany and Belgium have also made the greatest use of
voluntary agreements between government and the C&D industry to encourage
separation, re-use and recycling and good codes of practice for selective demolition, onsite
sorting and ‘closed life cycle’ approach to building materials, with reasonable
success.
5.68. The Symonds Report recommends one relatively simple administrative measure that
appears to have positive impacts and few negative side effects, and that is to introduce
a requirement for developers to provide a demolition plan with an associated C&D waste
management plan to the local authority before they are given permission to demolish a
building or structure.. This should result in developers having to weigh up the cost and
benefit factors associated with re-use and recycling of C&D waste, and thus taking the
time to consider selective demolition. The Symonds Report recommends that
demolition plans should be administered locally, but within a national policy framework
which acknowledges the value of such plans.
Recommendation 50: It is recommended that consideration should be given to how to
adopt, or influence Government to adopt, including those measures that have
been effective in achieving high recycling rates of C&D waste in other
European Member States, such as:
• Banning or partial banning landfill of C&D waste.
• Requiring separation and re-use/recycling of C&D waste.
• Encouraging the use of the Sustainable Construction Code of Practice, and
the Demolition Protocol.
• Working with the C&D industry and trade associations to establish targets,
and methods to encourage separation, re-use and recycling.
• Enabling waste planning authorities to require developers to provide a
demolition plan with an associated C&D waste management plan before
they are given permission to demolish a building or structure, and to attach
conditions to planning permissions/building permits to stimulate the use of
secondary materials.
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6. Special/Hazardous Waste
Introduction
6.1. The aim of this part of the project was to evaluate the current management strategies
for special/hazardous wastes in London, building upon the existing knowledge base, to
enable and inform the development of appropriate policies within the context of a wider
strategy for this waste stream. The specific objectives were listed in the project brief
and are repeated below. A summary of the key findings from this chapter is presented
in Chapter 7.
Identify and engage with key stakeholders, to include:
• Clarification of the position in terms of future treatment and management capacity for
hazardous waste and consideration of the recommendations/policies being proposed by the
Hazardous Waste Forum in terms of their potential impacts on hazardous waste management in
London.
• Assessment of the impact of growth in development in London, in terms of its effect on
special/hazardous waste generation and subsequent management.
• Consideration of possible options for raising awareness and waste prevention, minimisation and
recycling amongst hazardous waste producers.
• Assessment of the current and potential role of waste exchanges in London and the potential
opportunities available through the promotion of industrial symbiosis.
• Assessment of the effectiveness to date, and potential applicability of specific measures and
instruments to promote waste minimisation, recycling and diversion from landfill.
Background
6.2. The terms ‘special’ and ‘hazardous’ are defined as follows: ‘hazardous’ waste refers to
future waste arisings after the introduction of the Hazardous Waste Regulations (i.e.
essentially from summer 2005 onwards), whilst ‘special’ waste has been used to refer to
the current and historic situation which is regulated by the Special Waste Regulations
(1996). From herein, all wastes will be referred to as ‘hazardous’ to avoid confusion,
with the exception of legislative uses of the word ‘special’.
6.3. Hazardous waste in the UK is currently managed according to the Special Waste
Regulations (1996) which implements the Hazardous Waste Directive (91/689/EC).
Special wastes are those on the Hazardous Waste List (HWL, created by Commission
Decision 94/904/EC) and possessing any of 14 hazardous properties.
6.4. The European Waste Catalogue (EWC), created by European Commission Decision
94/3/EC, classifies all waste using a six-digit code system based on the source of the
waste. The HWL lists the wastes on the EWC considered to have hazardous constituents
above certain thresholds.
6.5. A review in 1997 resulted in the two classification systems (EWC and HWL) being
merged, with hazardous wastes indicated by the attachment of an asterisk to the sixdigit
code. The product of the amalgamation is the revised European Waste Catalogue,
created by European Commission Decision 2000/532/EC (as amended), adopted by the
EU on 1 January 2002.
6.6. The revised EWC identifies a wider range of hazardous wastes than that previously
assigned hazardous status. The new classification identifies an additional 250
95

categories of materials which were not previously considered as hazardous (e.g.
computers, fluorescent tubes, batteries and televisions). The introduction of the new
regulations is expected to significantly increase the total quantity of hazardous waste
(and the number of hazardous waste producers) in the UK.
6.7. Due to changes in the EWC and related legislation, and an aim to bring the UK
definition of hazardous waste into line with the EU definitions, DEFRA plans to replace
the Special Waste Regulations (1996) with the Hazardous Waste Regulations. The
introduction of the new hazardous waste regulations was proposed for mid 2004,
however it now appears that the introduction of the new legislation will be delayed until
1 st August 2005, in order to ensure compatibility with the WEEE Directive, Landfill
Directive and the Waste Acceptance Criteria (refer paragraph 6.8). The new
implementation date will coincide with the introduction of several other regulations, and
it is anticipated will lead to a significant increase both in the quantities of hazardous
waste arisings in the UK and the number of producers of hazardous waste. In addition,
the new regulations will require organisations producing hazardous waste to register
with the Environment Agency.
6.8. The EC Landfill Directive requires landfill operators to check that all waste entering the
landfill meets the Waste Acceptance Criteria (WAC). The WAC set limits for a number of
contaminants to meet the EC Landfill Directive with the aim of introducing testing
procedures for describing the characterisation of the waste and checking its compliance
with the acceptance criteria and to allow on-site verification. The Directive must be
transposed into UK legislation by 16 th July 2004 and must be in force by 16 th July
2005 35 .
6.9. The EC Landfill Directive will involve several changes to the management of hazardous
waste that will apply from the 16 th July 2004. Firstly, operators must classify their
landfill sites as either hazardous, non-hazardous, or inert and the co-disposal of
hazardous and non-hazardous wastes is prohibited. These requirements will greatly
reduce the number of landfill sites available for the disposal of hazardous waste. In
addition, wastes must be treated prior to disposal to reduce volume and hazardous
content; if the treatment process renders the waste ‘non-hazardous’ then it may go to a
separate cell in a non-hazardous landfill, whereas wastes still classified as hazardous
after the treatment process will be required to be sent for disposal at a designated
hazardous landfill.
Approach
6.10. In preparation of the new legislation, the Government established the Hazardous Waste
Forum in December 2002. The role of the Hazardous Waste Forum was to bring
together the key stakeholders to advise on the appropriate way forward in the light of
the new legislation for hazardous waste. The Hazardous Waste Forum has highlighted
the key issues of concern within the hazardous waste industry, as well as commissioning
work on waste arisings and treatment capacities. A summary of the work by the
Hazardous Waste Forum is presented in a report titled ‘Hazardous Waste – an action
plan for its reduction and environmentally sound management’ which was published in
2003 and is available on the internet 36 .
6.11. A variety of studies have previously been carried out on hazardous waste arisings. For
London in particular, the GLA commissioned Enviros Consulting Ltd to produce a
35 Defra Consultation outcome on Landfill Directive Waste Accpetance Criteria, March 2004.
36 http://www.defra.gov.uk/environment/waste/hazforum/actionplan/hwf-actionplan.pdf
96

‘Technical Assessment for Waste Management in London’ which documents 1998/99
and 2000 figures for hazardous waste obtained from the Environment Agency Waste
Interrogator 37 . Hazardous waste arisings collated by the Environment Agency can be
broken down into sub-regional data and have been documented in a variety of reports,
most notably:
• Strategic Waste Management Assessment 2000: London.
• Hazardous Waste Forum reports, prepared by Enviros.
• Technical Assessment for Waste Management in London (Enviros, April 2003).
6.12. The Environment Agency remains the most accurate and detailed source of information
on hazardous waste.
6.13. It should be noted that the Corporation of London provides a hazardous waste
collection and disposal service to all the London borough councils to collect and dispose
of small quantities of asbestos and chemicals. The service is primarily aimed at
households although hazardous materials do get collected from schools, registered
charities, borough offices and, increasingly, fly-tipped wastes. The contract is carried
out on behalf of the Corporation by CSG Lanstar which collects the chemicals and Biffa
Waste Services which collects the asbestos.
Data Collection and Validity
Data Collection
6.14. Under the Special Waste Regulations (1996), hazardous wastes are tracked by the
Environment Agency from their place of origin to their final destination (from cradle-tograve).
The system uses consignment notes which record details of the waste being
transported, with a new consignment note for each trip. Copies of the consignment
notes are sent to the Environment Agency where the information is put into the
Environment Agency’s Special Waste Tracking System (SWaT). Information from SWaT
is then summarised and made publicly available from the Hazardous Waste Interrogator
on the Environment Agency website 38 .
6.15. The Environment Agency’s Hazardous Waste Interrogator contains information on
wastes produced, waste disposed, waste type, waste fate, and waste movements. The
data covers 1999, 2000 and 2001 and is available at a London region, sub-region
(Central, South, West London), and local authority level. In addition, summary figures
for the arisings and fate of hazardous waste are available for 2002. The 2002 data is
available at the London (region) level only. The 2002 figures cannot be interrogated for
waste type going to landfill, or type of waste to treatment, as is currently possible with
earlier data on the Hazardous Waste Interrogator. From 2001, SWaT figures will not be
published through the Hazardous Waste Interrogator due to the aging interface and a
new interrogational software is currently under development.
Data Validity
6.16. The data from the consignment note system is used to provide information on the
arisings of hazardous waste. However, the nature of the system can result in
inaccuracies due to double counting, under-counting, or wastes by-passing the tracking
system completely. These problems are discussed below.
37 A web based tool which can be used to interrogate the information collected from the consignment notes in a
variety of ways. For example, by authority, waste arising, waste disposed etc.
38 http://www.environment-agency.gov.uk/apps/wastesurvey2/?lang=_e
97

6.17. Hazardous wastes may be transported directly from their point of production to the
point of disposal in a single journey. In these cases, the consignment notes provide an
accurate indication of hazardous waste arisings.
6.18. Alternatively, hazardous waste may be transported in multi-stage journeys from the
point of production to the point of disposal. This may be for a number of reasons such
as transport logistics, for intermediate bulking or sorting, and also for intermediate
treatment. Since each journey requires an additional consignment note, each additional
movement of the waste will result in double counting by the consignment note system.
6.19. Processing of hazardous waste may also result in data validity uncertainties under the
current consignment note system. Where hazardous wastes are processed on the site of
production, the waste data may not be recorded (refer para 6.19) and lead to underreporting.
Hazardous waste may cease to be defined as ‘hazardous’ after processing,
and will therefore no longer be recorded using the consignment note system. Where
the processing is carried out by a different company (or by the same company but on a
different site to the production site), then this hazardous waste will have already been
recorded through the consignment note system and the processing will not result in
double counting. Some double counting can also occur where the processing does not
result in the waste being re-classified as non-hazardous, but rather changes its physical
or chemical properties prior to disposal.
6.20. Hazardous waste managed at the site of production may include, for example, liquid and
sludge (generally referred to in terms of volume) from the manufacture of chemicals or
metals that is treated or disposed on site. Such treatment can reduce the volume and
change the properties of the waste. The result may be that wastes which would have
been designated as hazardous are no longer hazardous wastes, or that the volume of
waste to be designated as hazardous waste is reduced. Such wastes are excluded from
the data recorded on consignment notes of the arisings of hazardous waste, although
this data is recorded on a separate confidential database (refer para. 6.24). Other ways
in which the consignment note system may fail to capture all hazardous waste arisings
are noted in the following paragraphs.
6.21. The consignment note system may also fail to identify waste that is illegally handled.
For example, a company that transports its own waste to a point of treatment or
disposal where the receiver does not ask for a consignment note will not be included in
the consignment notification system. This may be due to ignorance of the regulations
or a decision to not follow the regulations. Either way, failure to notify means that
hazardous waste arisings are not recorded.
6.22. Fly-tipping is another way in which hazardous waste can fail to be defined at the point
of origin. However, the removal of fly-tipping is a statutory duty of local authorities
and therefore any hazardous waste in the fly-tipped material should be captured by the
notification system, albeit not at the point of production. Therefore from the
perspective of total tonnage of arisings, fly-tipping should not result in hazardous
wastes being excluded from the total arisings figures.
6.23. In summary, the consignment note system was designed to provide data for the
Environment Agency’s SWaT database about the movements and quantities of special
waste, under the Special Waste Regulations, 1996. However the system was not
designed to take account of the complexities arising from multi-stage movements and
the processing of hazardous wastes on the site of production, and any resulting volume
reduction or elimination. Hence the current system does not provide a completely
98

accurate record of hazardous waste arisings and movements, taking these complexities
into account.
6.24. Based on the current, publicly available hazardous waste data from the Environment
Agency, it is not possible to reach a conclusion about the likely extent of any
inaccuracies in the hazardous waste data. However the Environment Agency has
indicated that it believes that overestimation through double counting is not a
significant issue for data certainty. In addition, hazardous wastes which are treated on
the site of production (and therefore excluded from the consignment note system and
the SWaT database) are separately recorded by the Environment Agency in a
programme called RATS (basis of acronym unknown). However, the information from
this system is not publicly available, due to its potential commercially sensitive nature.
However the Environment Agency (Debbie Ely) has indicated that if the GLA wishes to
pursue research into the extent of on-site treatment of hazardous waste in London, a
written request could be made to the Environment Agency for this information for
London, and the Agency, if it felt it could provide the information in a non-commercially
sensitive form, would respond in due course to this request.
6.25. The RATs database is separate from the SWaT database and records hazardous wastes
produced AND treated onsite. The data is collected through site return forms and
logged on the RATs database. Information on the amount of waste treated onsite, for
any site in London which produces and treats its own hazardous waste, will be contained
on the RATs database.
6.26. The Environment Agency has future plans to re-design the hazardous waste data
recording system in accordance with the reporting requirements set out in the new
Hazardous Waste Regulations. It is expected that the revised system will present data in
an import-export fashion, with the aim that hazardous waste consignment notes can be
traced and that the opportunity for double counting or data omissions is reduced.
6.27. The Environment Agency believes that the potential for over reporting of hazardous
wastes due to the current practice of notification of mixtures of hazardous and nonhazardous
wastes as all hazardous, is likely to be a more significant cause of over
reporting of hazardous waste than double counting due to multiple movements. When
hazardous and non-hazardous wastes are mixed, the entire waste mixture is classified as
hazardous, leading to an increase in the quantity of hazardous waste reported. While it
is believed that this practice is commonplace, there is however no mechanism to
account for this in current hazardous waste arisings data reporting systems.
Hazardous Waste Arisings
Overview of Hazardous Waste in England and Wales
6.28. A total of 5.08 million tonnes of consigned hazardous waste was produced in England
and Wales in 2002 (Environment Agency Waste Summary Tables for 2002). Overall in
England and Wales 70% of hazardous waste came from just four of the 20 EWC
categories:
• 25% formed by construction and demolition waste and asbestos;
• 20% formed by oil and oil/water mixtures;
• 12% formed by wastes from organic chemical processes;
• 13% formed from EWC 99 – ‘not otherwise specified’ category.
99

6.29. A breakdown of the hazardous waste arisings by region is shown in Figure 6.1. In
2002, a total of 458,579 tonnes of hazardous waste was produced in London (SWaT,
2002). This is approximately 9% of the total hazardous waste arisings for England and
Wales and makes London the sixth highest producing region in the country.
6.30. However, the average hazardous waste production per person in London is less than the
average production per person figures for England and Wales, and the UK. On average,
the hazardous waste production per person per year in London is 63.9kgs, compared to
92.1kgs in England and Wales and 86.0kgs for the UK. This information was calculated
using the Environment Agency hazardous waste production information for 2002, and
the 2001 Census information as the most up to date population data..
Hazardous Waste Produced (000's tonnes)
800
700
600
500
400
300
200
100
-
Figure 6.1: Summary of hazardous waste arisings in England and Wales by
region (2002)
East Midlands East of
England
SWat 2002: Hazardous waste arisings by region.
London North East North West South East South West Wales West
Midlands
Yorks &
Humber
6.31. A complete breakdown of hazardous waste arisings by European Waste Catalogue
(EWC) code for London is illustrated in Figure 6.2.
100

Figure 6.2: Breakdown of recorded hazardous waste arisings in London by EWC (SWaT 2002). Total Hazardous Waste Arisings
= 458,579 tonnes
Petrol, Gas and Coal
Refining/Treatment
EWC05, 284t , 0%
Wood and Paper Production
EWC03, 1t , 0%
Agricultural and Food Production
EWC02, 56t , 0%
Unclassified
EWC99, 895t , 0%
Municipal and Similar
Commercial Wastes
EWC20, 704t , 0%
Mining and Minerals
EWC01, 46t , 0%
Waste/Water Treatment and
Water Industry
EWC19, 33,198t , 7%
Healthcare
EWC18, 2,331t , 1%
Source: Environment Agency 2002
Organic Chemical
Processes
EWC07, 5,311t , 1%
Inorganic Chemical
Processes
EWC06, 9,974t , 2%
C&D Waste and Asbestos
EWC17, 334,558t , 73%
MFSU Paints, Varnish,
Adhesive and Inks
EWC08, 6,032t , 1%
101
Photographic Industry
EWC09, 2,464t , 1%
Thermal Process Waste
(inorganic)
EWC10, 943t , 0%
Metal Treatment and Coating
Processes
EWC11, 6,702t , 1%
Shaping/Treatment of Metals
and Plastics
EWC12, 2,521t , 1%
Oil and Oil/Water Mixtures
EWC13, 38,085t , 8%
Solvents
EWC14, 1,145t , 0%
Packaging, Cloths, Filter
Materials
EWC15, 1,152t , 0%
Not Otherwise Specified
EWC16, 12,175t , 3%

6.32. Approximately 73% (334,558 tonnes) of the hazardous waste arisings in London
originate from ‘construction and demolition waste and asbestos’. There is no further
breakdown of this EWC group for the most recent (2002) SWaT data. However the
2001 data is broken down further and indicates that of the 345,851 tonnes of
hazardous C&D waste recorded in 2001, 235,641 (68%) was composed of soils and
stones (EWC 170501) indicating that a high percentage of the hazardous waste in the
‘construction and demolition and asbestos’ category comprises contaminated soils from
the re-development of brownfield sites This concurs with the view expressed in the
Environment Agency report ‘Hazardous Waste – A Growing Challenge’ 39 . The other
main individual contributors towards hazardous waste arisings in London are:
• oil and oil/water mixtures (~8%, 38,085 tonnes);
• the waste water treatment and water industry (~7%, 33,198 tonnes); and
• inorganic chemical processes (~2%, 9,974 tonnes).
Waste Movement
6.33. Table 6.1 documents the hazardous waste movements between regions. In terms of
hazardous waste disposal, London is the least self-contained region in England and
Wales since it only treats and disposes of 3.7% of the hazardous waste it produces
(Environment Agency, 2002). The predominant trend in the South East is the largescale
movement of hazardous waste out of London (441,700 tonnes in 2002) into the
surrounding regions.
Table 6.1: Movements of hazardous waste between regions in England and
Wales (Environment Agency, 2002)
Planning Region
East East of North North
London
Midlands England East West
South
East
South
West
Wales
West Yorks &
Midlands Humber Total
produced
East Midlands
East of England
London
North East
North West
South East
South W est
Wales
W est Midlands
Yorks & Humber
Total deposits
imports
112.7 10.4 1.4 1.4 21.0 3.5 1.4 2.4 32.6 66.4 253.3
14.3 316.7 6.6 0.3 13.4 27.6 4.0 4.4 8.5 29.4 425.2
16.8 302.3 16.9 0.3 8.7 73.9 15.0 3.6 6.0 15.0 458.6
exp 24.8 6.4 0.1 166.7 43.4 21.7 0.3 1.9 3.6 44.3 313.1
orts 38.1 9.0 0.0 5.8 489.1 7.2 5.3 19.7 29.6 41.2 644.8
15.2 154.7 9.9 2.2 17.0 230.9 96.6 12.0 22.3 17.9 578.7
10.1 15.2 0.5 0.1 16.6 18.9 183.6 24.2 24.0 10.7 279.8
9.5 8.8 0.0 0.1 33.9 5.7 16.3 560.0 38.3 9.4 682.1
49.9 13.8 0.1 23.5 41.2 4.8 18.5 21.5 342.1 26.2 541.6
75.0 24.5 0.0 10.5 95.5 16.4 1.1 0.5 11.9 381.9 617.4
366.3 861.8 35.6 210.9 780.0 410.6 342.2 650.1 518.9 642.5 4,794.6
Does not include movements from Scotland and Northern Ireland, or records where no region has been allocated.
6.34. From Table 6.1 it can be seen that London exports hazardous wastes to all regions of
England and Wales. The largest receiving region by far is the East of England (302,300
tonnes) followed by the South East (which receives 73,900 tonnes). The East Midlands,
South West, and Yorkshire and Humber each receive c.15 thousand tonnes, with the
North West at 8.7 thousand tonnes and West Midlands at 6.0 thousand tonnes. Wales
receives a relatively small amount (3,600 tonnes) and very little is sent to the North East
(300 tonnes).
6.35. Table 6.1 indicates that London imported 18,700 tonnes of hazardous waste in 2002.
This is lower than the tonnage imported by any other region. As a comparison of the
magnitudes of imports, the North-East is the second smallest importer of hazardous
waste (44,200 tonnes). Not surprisingly, the two highest regions that export hazardous
39 Hazardous Waste – A Growing Challenge, Environment Agency, February 2004
102

wastes to London are the closest, i.e. the South East (9,900 tonnes) and the East of
England (9,600 tonnes) (2002 figures). Exports from all other regions are relatively
insignificant.
6.36. Hazardous waste imports and exports cannot be broken down further into waste
categories as the 2002 data is currently only available as summary sheets and cannot be
analysed in more detail using the Environment Agency Waste Interrogator.
6.37. As an aid to gaining an understanding of London’s current hazardous waste treatment
industry, import data from the Environment Agency hazardous waste interrogator was
analysed. The assumption was that any hazardous waste being imported into London -
although the amounts are relatively small (as outlined above in paragraph 6.33) - would
give an indication of the types of hazardous waste treatment facilities in London. The
information below is based on 2001 data, the most recent data available for
interrogation.
6.38. The total amount of hazardous waste imported by London in 2001 was recorded as
45,312 tonnes. Note this is significantly different from the 18,700 tonnes reported by
the EA in Table 6.1. Of this, 14,455 tonnes were treated in London, with three EWC
categories making up the majority of the treated waste. Table 6.2 indicates that if the
import and treatment correlation assumption is correct, then London has a significant
treatment capacity for Oil and Oil/Water Mixtures.
Table 6.2: Breakdown of Hazardous Wastes imported into London for
treatment
EWC Waste Type Tonnes % of total
05 Petrol, Gas & Coal Refining 946 6.5
12 Shaping/Treatment of Metals & Plastics 3,283 22.7
13 Oil & Oil/Water Mixtures 10,127 70.1
Other 99 0.7
Total: 14,455 100
Waste Disposal
6.39. Although London produced 458,579 tonnes of hazardous waste in 2002, only 56,364
tonnes were disposed of in the London region (including imports). The major fates for
London’s hazardous wastes are presented below in Figure 6.3 from which it can be
seen that the majority are either treated (43%, 23,970 tonnes), landfilled (36%, 20,509
tonnes), or recycled/reused (13%, 7,373 tonnes).
103

Figure 6.3: Fate of hazardous wastes in London (SWaT 2002, total disposals
56,364 tonnes)
Treatment, 23970, 43%
SWat 2002: Hazardous waste deposits by fate for London
Incineration with energy
recovery, 157, 0%
Incineration without
energy recovery, 315, 1%
Transfer (Short term),
3919, 7%
Recycling / reuse, 7373,
13%
Landfill, 20509, 36%
Long term storage, 121,
0%
6.40. Figure 6.4 shows the breakdown of wastes (by EWC code) disposed of in London in
2002. Of the 56,364 tonnes of wastes treated or disposed of in London, 75% (41,773
tonnes) arise from 2 EWC categories. Note this is significantly different from the 35,600
tonnes reported by the EA in Table 6.1. These are approximately 40% (22,367 tonnes)
from oil and oil/water mixtures (EWC 13) and 35% (19,604) tonnes of construction and
demolition and asbestos waste (EWC 17). While it appears that London has some local
capability to process oil and oil/water mixtures, any local landfill capacity to accept
hazardous construction and demolition waste and asbestos will disappear from 16 July
2004. The introduction of revisions brought about by the Landfill Directive will result in
significant increases in disposal costs from this date, due to the greater distance to
licensed landfill sites and additional treatment costs. This may act as an incentive to
reduce hazardous wastes from construction sites through better on-site analysis.
104

Figure 6.4: Breakdown of hazardous wastes disposed in London by EWC (SWaT 2002). Total Hazardous waste disposals =
56,364 tonnes
Agricultural and Food Production
EWC02, 88t , 0%
Unclassified
EWC99, 51t , 0%
Municipal and Similar
Commercial Wastes
EWC20, 16t , 0%
Healthcare
EWC18, 507t , 1%
C&D Waste and Asbestos
EWC17, 19,604t , 35%
Not Otherwise Specified
EWC16, 5,643t , 10%
Source: Environment Agency 2002
Wood and Paper Production
EWC03, 24t , 0%
Packaging, Cloths, Filter
Materials
EWC15, 166t , 0%
Petrol, Gas and Coal
Refining/Treatment
EWC05, 620t , 1%
Solvents
EWC14, 538t , 1%
105
Inorganic Chemical Processes
EWC06, 131t , 0% Organic Chemical
Processes
EWC07, 562t , 1%
Oil and Oil/Water Mixtures
EWC13, 22,367t , 40%
MFSU Paints, Varnish,
Adhesive and Inks
EWC08, 1,497t , 3%
Photographic Industry
EWC09, 2,393t , 4%
Thermal Process Waste
(inorganic)
EWC10, 0t , 0%
Metal Treatment and Coating
Processes
EWC11, 4t , 0%
Shaping/Treatment of Metals
and Plastics
EWC12, 2,154t , 4%

Waste Growth
6.41. Overall, the Environment Agency has reported no growth in consigned hazardous waste
arisings for England and Wales between 1998/99 to 2002, with construction and
demolition and asbestos, and oil and oil/water mixtures comprising the majority of the
hazardous waste throughout.
6.42. However, although there has been no growth in consigned hazardous waste in England
and Wales, the pattern of arisings in London over the last 4 documented years is rather
erratic, with annual fluctuations of up to 45%. This is shown in Table 6.3 which
indicates that there was a decline by nearly 50% between 1999 and 2000, a significant
increase between 2000 and 2001, and a small decline between 2001 and 2002.
Table 6.3: Summary of hazardous waste arisings in London since 1999 (SWaT)
1999 2000 2001 2002
Waste Arisings 652,814 360,983 497,056 458,579
% Annual Growth Not known -44.7% 37.7% -7.7%
6.43. The reasons for the fluctuations in the annual arisings of hazardous wastes in London
are not known at present and may possibly be a result of poor understanding of the
waste recording and reporting requirements. These recorded changes in consigned
hazardous wastes in London are unlikely to represent a true reflection of actual changes
in hazardous waste arisings. Rather, the fluctuations are likely to result from the data
validity uncertainties over the consignment note system discussed earlier and reflect the
complexity of the reporting system (which often results in the over reporting of waste)
and confusion on the part of waste producers.
Landfill Capacity
6.44. Quoted figures for the landfill disposal of hazardous wastes vary from around 2 million
tonnes (Environment Agency, 2002, England & Wales) to 2.5 million tonnes (the
Hazardous Waste Forum, UK total). Based on Environment Agency data, landfill
disposal is currently the main fate of hazardous waste in England and Wales at 39%,
with around 25% of the total being treated, 20% recycled and 5% incinerated.
6.45. In 2000, 71% of the hazardous waste exported from London was sent to landfill
(Enviros, 2003) and it is reasonable to assume that a similar proportion of the 441,700
tonnes of waste exported in 2002 (i.e. 313,600 tonnes) was also landfilled. Using this
assumption, a total of 334,100 tonnes (~73% of London’s total hazardous waste
production) was landfilled in 2002, including hazardous waste landfilled in London
(20,500 tonnes). It is likely that the majority of this waste went to landfill untreated.
6.46. Recent figures on the types of landfill site in England and Wales (published by the
Environment Agency in 2003) identify a total of 83 landfills accepting hazardous waste
only and a further 286 which are co-disposal sites. Under the Landfill Directive, codisposal
of hazardous waste with non-hazardous waste will be banned from 16 th July
2004, and treatment standards will be set for hazardous waste prior to landfill.
Therefore, only hazardous waste landfills will be able to accept hazardous waste and the
number of available sites will be reduced.
107

6.47. There are a range of views from people involved in the hazardous waste industry about
the number of landfill sites remaining nationally that will be able to accept hazardous
waste after 16 th July 2004. Estimates of around 35 sites are given in ‘Hazardous Waste
– A Growing Challenge’ 40 . Alternatively, the National Household Hazardous Waste
Forum (Roland Arnison, Manager) suggests that there may only be ‘12 to 15 hazardous
landfills across England’ in the short term after 16 th July 2004.
6.48. Information presented by Gill Weeks (Regulatory Affairs Director, Cleanaway) at the
Hazardous Waste Summit (24 th March 2004) identified the potential future landfill
capacity (post July 2004) in England and Wales as:
• 12 merchant hazardous landfill applications/permits;
• 11 in-house applications permits; and
• 28 applications for separate cells (for stabilised hazardous wastes).
6.49. The list given above is of potential hazardous landfill sites; these are estimated to have a
total capacity of approximately 1 million tonnes. However, this capacity is not fully
available as many sites will only be able to accept limited types of hazardous wastes e.g.
asbestos. This will potentially leave only a handful of landfills across the country with
the ability to accept a wide range of hazardous wastes. In addition, only a small number
of landfill sites have currently been granted a licence.
6.50. The Environment Agency posted a list of landfill sites where operators have submitted
duly made applications to the Agency to continue to accept hazardous waste after 16
July 2004. This information (current as at 20 th April) is presented in Tables 6.3 and
6.4, identifying 13 Merchant Landfills and 9 In-House Landfills. Of the 13 Merchant
Sites, only 5 permits have been issued, 2 of which are licensed to accept asbestos only,
with the remaining 2 accepting a range of hazardous wastes (Kingscliffe, Northants;
Stockton on Tees, Teeside; and Swindon, Wilts). However, at present, it cannot be
assumed that this expected capacity will actually be realised since not all of the
identified sites have yet been permitted.
6.51. Assuming that the landfill capacity to accept hazardous waste in England and Wales is
around 1 million tonnes and with the disposal of hazardous waste being directed to
landfill in 2002 being approximately 2 million tonnes, it is apparent that after 16 th July
2004 there will be a very significant shortfall in landfill capacity for the disposal of
hazardous waste. This deficit will be further aggravated by the introduction of the new
definitions of hazardous waste in 2005 and the consequential increase in hazardous
waste, which the Hazardous Waste Forum estimates will result in an additional 0.8
million tonnes of waste above current tonnages. This will be a step change in the total
hazardous waste produced, due to the change in regulations scheduled for mid-2005,
rather than organic growth. Hence, for England and Wales, the combined effects of the
Hazardous Waste Regulations and the Landfill Directive are expected to result in a total
annual shortfall of some 1.8 million tonnes of landfill capacity – with 1.0m shortfall
anticipated in mid-2004 and a further 0.8 million tonnes in mid-2005.
6.52. Last year, the Government and the Environment Agency were optimistic that some of
this shortfall may be addressed through the engineering and permitting of separate cells
at non-hazardous landfill sites for stabilised hazardous waste. However, at a recent
Hazardous Waste conference in London, the view from industry was that separate cells
were unlikely to make up a significant amount of the shortfall in the short to medium
40 Hazardous Waste. A growing challenge. Environment Agency, February 2004
108

term. The stated reason for this was given as the delays in the Environment Agency’s
publication of guidance on the engineering requirements for separate cells.
Table 6.4: Merchant landfills which have submitted duly made applications to
the Environment Agency (20 April 2004)
Merchant Landfills for Hazardous Waste (20 April 2004)
1
2
Site Name Operator Location
Earlswick Hall Brock plc Crewe, Cheshire North
West
ICI no. 3 Impetus Waste Teeside North
Management.
East
EA
Region EA Area SPG
Range of Hazardous
Wastes Permit Status
South W Contaminated soils To be determined
Dales W Wide range of hazardous
wastes
To be determined
3
Whitemoss J. Routledge and Skelmersdale, Lancs.
Sons
North
West
Central W Wide range of hazardous
waste
To be determined
4
Port Clarence Zero Waste Teeside, Stockton on Tees North
East
Dales W Wide range of hazardous
wastes
Permit Issued
5 Winterton
South
Integrated
Waste
Winterton, North Lincs. Anglian Northern N Wide range of hazardous
wastes
To be determined
Meece 2
Management Ltd
Biffa Stone, Staffs. Midlands Upper N Limited range of 'Chapter To be determined
6
Trent
19' Haz wastes: 19 01 05*,
19 01 07*, 19 01 10*, 19
01 13*, 19 01 15*
7
8
9
Warboys Fenside Waste
Management
Wingmoor
Farm
Southwood
Landfill
Huntingdon, Cambs. Anglian Central N Wide range but slightly
narrower range and lower
quantities than existing
WML allows
Grundon Cheltenham, Glos. Midlands Lower
Severn
Southwood
Waste
Management
Shepton Mallett, Somerset South
West
North
Wessex
B Wide range of hazardous
waste. Generally higher
inputs of HW than
previously licensed
B Asbestos only. Quantity is
same as current WML
To be determined
To be determined
Permit Issued
Pinden Quarry Pinden Plant
10
Dartford, Kent Southern Kent B Asbestos only. Quantity is Permit Issued
same as current WML
Purton Hills Minerals Swindon, Wilts Thames West B Range includes
Permit Issued
11 Brickworks and Waste Ltd
contaminated soils, filter
cakes, packaging
12 Slipe Clay Atlantic Waste Kingscliffe Anglian Northern Area Wide range of wastes Permit Issued
cliffe,
Kingscliffe
Services
13 Winsford Rock Minosus Winsford, Cheshire North South Range of inorganic, non- Planning issues to be
Salt Mine
West
flammable waste currently resolved
in negotiation with Agency
over detail of waste types
SPGs KEY N: Nottingham W: Warrington B: Bristol
109

Table 6.5: In-house landfills which have submitted duly made applications to
the Environment Agency (20 April 2004)
In-House Landfills for Hazardous Waste (20 April 04)
Site Name Operator Location EA Region EA Area SPG Range of Hazardous
Wastes
Permit
Status
1 Bradley Park Syngenta Huddersfield, North East Ridings N Wide range of wastes To be
Landfill
West Yorkshire
determined
2 Grange Top Castle Cement Ketton, Nr Anglian North N Haz (Cement Kiln Dust) Permit
Quarry
Stamford
only
Issued
3 Rugby Works Rugby Cement Rugby, Warks Midlands Lower Severn B Cement Kiln Dust and on To be
site roadsweepings determined
4 Southam Rugby Cement Southam, Warks Midlands Lower Severn B Cement Kiln Dust and on To be
site roadsweepings determined
5 Alcan Pot Linings Alcan Aluminium Newbiggin, North East Northumbria W Spent pot linings To be
Northumberland
determined
6 Coplow Quarry Castle Cement Clitheroe,
Lancashire
North West Central W Cement Kiln Dust Refused
7 Royal Ordnance BAE Systems Chorley, Lancs North West Central W Contaminated land and Permit
Landfill
other haz waste including Issued
asbestos
8 Randle Landfill Ineos Chlor Ltd Runcorn, North West South W Treated haz wastes To be
Cheshire
arising from the chemical determined
manufacturing process
SPGs KEY
N: Nottingham W: Warrington B: Bristol
6.53. Landfills listed in Table 6.5 are in-house landfills. Therefore, although they have
capacity for hazardous waste, this is not a widely available commercial capacity as the
landfill capacity will be used by the host company alone. Hence, these landfills do not
add any additional capacity for London’s hazardous wastes.
6.54. After implementation of the new regulations there is expected to be just one landfill
accepting hazardous waste in the South East area; i.e. the Pinden Quarry in Dartford.
However, this is only licensed to accept asbestos. The PF Ahern (London) Ltd. landfill
that used to accept asbestos is now closed and being remediated. The current lists of
hazardous landfills indicates that the closest hazardous landfill which is applying for
permission to receive a range of hazardous wastes is Huntingdon, Cambs (approximately
76 miles from central London), while the closest site currently with a permit is
Kingscliffe, Northants (approximately 90 miles away from central London).
6.55. An accurate assessment of the landfill capacity is difficult to make in a situation where
PPC permits have yet to be determined. However, it is clear that landfill capacity for
most hazardous waste in the London area will be non-existent, with pre-treated waste
having to travel long distances (at least 75 miles) before disposal.
6.56. It is quite possible that the process of permitting will not be completed for all the sites
until shortly before the July 2004 deadline.
Recommendation 51: It is recommended that caution should be exercised in relation
to the number of hazardous wastes landfill sites that it is anticipated will
become available in the near future; rather the situation should be monitored
during the next few months since the actual number of permitted hazardous
waste sites may vary significantly from that predicted.
6.57. As previously noted, around 73% of the hazardous waste arisings in London are from
the ‘construction and demolition and asbestos’ waste category, of which a large
proportion are contaminated soils (Figure 6.2) . Whilst there is no current alternative to
landfill for asbestos, there are a range of alternative treatments available for
110

contaminated soils, although these are not currently used to a great extent in the UK.
Therefore, the greatest potential for reducing the amount of London’s hazardous waste
to be landfilled is most likely to be achieved through focusing on contaminated soils. It
should be noted that the transport and disposal of contaminated soils is often a very
significant proportion of the costs of brownfield site redevelopment and thus hazardous
waste landfill shortages may theoretically encourage more on-site contaminated land
remediation. It is likely that the final decision may be determined by time, space and
cost constraints.
6.58. There are a range of technologies available which are capable of on-site treatment of
contaminated soils, either through bioremediation, solvent extraction, or immobilisation
(mixing the waste with other constituents such as concrete which will immobilise the
hazardous components). These are discussed in more detail in the next sub-section.
6.59. The Environment Minister Elliot Morley commented that when co-disposal ends in July,
the costs of disposal for contaminated soils could increase by 10-100%, depending on
factors including pre-treatment (which can both increase and decrease volume), greater
incentives for on-site treatment (which would decrease demand for landfill), and
increasing costs which will provide a strong incentive to minimise, recycle and re-use
such soils (Resource Management and Recovery, 5 th March 2004).
6.60. The DEFRA representative at the recent Hazardous Waste Conference 41 accepted that
the forthcoming regulations may have a significant impact on brownfield site
development in London. He suggested that it was entirely plausible that construction
on brownfield sites may be greatly curtailed in the short to medium term until suitable
treatment technologies are available to address this issue.
6.61. Therefore, it is likely that there will be significantly increased costs associated with
brownfield site development in London. This could affect brownfield site development
in the short to medium term.
Recommendation 52: It is recommended that in response to the prohibition of codisposal
of hazardous and non-hazardous waste urgent consideration is given
to the opportunities for on-site treatment of contaminated soils, and the way
in which the resultant increased costs of brownfield site development may
affect other policy objectives (eg. housing provision, as well as short to
medium term commercial development).
Alternatives to Landfill
6.62. From 16 July 2004, in London and the UK as a whole, there is expected to be a
significant shortfall in facilities available to treat hazardous waste, including landfill
capacity. If the breakdown of hazardous waste arisings in London remains similar to
that in 2002 (refer Figure 6.2), then the treatment capacity required for hazardous
waste produced in London after July 2004 will be in excess of 330,000 tonnes.
6.63. In 2002 the treatment of hazardous wastes in London accounted for approximately
24,000 tonnes (refer Figure 6.3), less than 8% of the required capacity. Since the
figures of the amount of waste exported to treatment are unknown, the treatment
capacity required to handle London’s hazardous waste could be in excess of 330,000
tonnes p.a. as stated above. This estimate excludes the additional capacity
41 letsrecycle.com Conference, Hazardous Waste Summit, 24 th March 2004
111

equirements for the ‘new’ hazardous wastes from mid-2005 (predicted as 0.8 million
tonnes for England and Wales, see below).
6.64. The work completed by the Hazardous Waste Forum and undertaken by the
Environment Agency refers to hazardous waste capacity and the impact in the change of
the definition from Special to Hazardous. The figure of 0.8 million tonnes per annum of
additional waste classed as hazardous (due to expansion in the definition of hazardous)
was produced by assessing the hazardous properties that different waste types possess,
and is for England and Wales.
6.65. There has been no additional work to date to provide a breakdown of this figure by
regions. However, estimations could be made into the amount of extra waste produced
by London based either on:
• London’s proportion of the current hazardous waste arisings (9% = 72,000 tonnes);
or
• London’s population in proportion to England and Wales (14% = 112,000 tonnes)
6.66. However, both of the above methods are likely to contain inaccuracies. Estimating on
the current proportions of hazardous waste production (using Consignment Notes)
would not take any account of future inputs from domestic production, whereas
estimates using population for different areas discounts the impact of the industrial
nature of the area. Nevertheless it is acknowledged that hazardous waste arisings will
increase significantly under the new regulations and that the increase in London could
be in the region of 100,000 tonnes per annum, i.e. an uplift of more than 20% on
London’s current hazardous waste arisings (458,579 tonnes).
Recommendation 53: In the light of the anticipated significant increase in hazardous
waste arisings under the new Hazardous Waste Regulations, it is recommended
that a separate investigation is carried out into the likely quantity and type of
these ‘new’ hazardous wastes to inform the development of a strategy to
improve the degree of London’s self-sufficiency in managing such wastes.
6.67. It is important to point out that the future lack of treatment capacity for hazardous
wastes is not a problem that is specific to London. The Hazardous Waste Forum has
made it clear to the Government that the treatment facilities throughout the country do
not exist to meet the stipulations of the EC Landfill Directive.
6.68. It is clear that a considerable increase in treatment capacity is required. It is also evident
that the waste management industry cannot provide this capacity at present due at least
in part to uncertainties regarding the requirements of the new regulations. Also a
considerable time period is required to plan, develop and construct new facilities. This
period can be variable due to the nature and location of the plant and the strength of
any public opposition. It is anticipated that it would take a minimum of at least one
year, and could well be several years to plan, authorise and construct new facilities.
Given that the hazardous waste provision in the UK is essentially provided by the private
sector, the industry has to be confident that they will be able to meet the regulations
and licensing requirements and procure appropriate disposal contracts before they
commence the planning and construction of multi-million pound developments. Hence,
even if an appropriate number of treatment facilities were commissioned immediately,
the lag time before they came on stream could be several years or more.
Recommendation 54: It is strongly recommended that in developing future policy for
waste management in London, the time required to plan, authorise and
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construct new facilities in providing hazardous waste treatment facilities
should be taken note of.
6.69. Assuming a perhaps rather optimistic lag time of three years and a London capacity
shortfall of around 330,000 tonnes per annum, this would indicate a total shortfall in
treatment capacity for hazardous wastes arising in London of some 1.0 million tonnes,
whilst with a lag time of five and seven years it could be some 1.6 and 2.3 million
tonnes respectively. However, taking account of the possible quantities of ‘new’
hazardous wastes likely to require treatment from mid-2005, London’s capacity shortfall
may actually be much higher, at 1.3m tonnes (3 years), 2.2 m tonnes (5 years) and 3.0
m tonnes (7 years).
6.70. An additional concern raised by the stakeholders of the Hazardous Waste Forum is the
actions of some landfill operators, who are reducing the cost of landfill in order to take
as much waste as possible before the 16 th July 2004 cut-off point. Waste managers are
concerned that an increased influx of hazardous waste to landfill in the next couple of
months could result in market distortions and a reduction in available future capacity.
This may also give a disincentive to early action by operators who are thinking of
investing in the hazardous waste treatment industry in the long term.
6.71. Plans for the development of new hazardous waste treatment facilities are unlikely to be
initiated until the new Hazardous Waste Regulations guidelines are available, in mid-
2004. It is clear that future treatment must change the characteristics of the waste to
decrease its hazardousness. It is not sufficient only to reduce volume.
6.72. Part of the scope of the Hazardous Waste Forum Capacity Sub-Group was to identify
and assess the most likely alternative treatment routes for hazardous waste which is
currently landfilled. The Environment Agency has also produced a report titled
‘Hazardous Waste Management – Market Pressures and Opportunities’ outlining some
of the treatment options. These are summarised briefly below:
• Stabilisation/solidification. Stabilisation is potentially an effective treatment for
contaminated soils and process-derived hazardous wastes. Under controlled
conditions waste can be processed from hazardous to non-hazardous waste prior to
landfill. The processes must meet the WAC and leaching limits.
• Physico-chemical treatment (reduction/oxidation, neutralisation, precipitation, air
stripping).
• Solvent recovery; this is generally applicable to organic wastes and is used to
separate hazardous substances from equipment, soil or sediment. The process
makes use of organic chemicals as solvents to dissolve and remove the contaminants
of concern from the soil, sediment or other solid matrix.
• Bioremediation. Biological processes change the characteristics of the waste, and
can reduce its mass, facilitate its handling, and may reduce its hazardousness. Often
used in waste water treatment and also in contaminated soil treatment (albeit
infrequently in the UK).
• Waste water treatment works. The waste water treatment industry holds the
potential to handle a wide range of liquid hazardous waste, either at a sole
treatment facility, or following some other pre-treatment. The Environment Agency
suggests in the document ‘Hazardous Waste Market Pressures and Opportunities’
that industrial companies could pre-treat their wastes on-site to make them suitable
for discharge to the trade effluent sewer. Water treatment companies are looking at
113

options to improve treatment, such as biological treatment, acid neutralisation, alkali
treatment, chromic acid treatment, cyanide treatment, precipitation, settlement,
dewatering, filtration, immobilisation, oil processing and blending.
• HTI (High Temperature Incineration). HTI can achieve up to 99.99% destruction
efficiencies. It removes organic material and leaves an ash. Currently HTI is used for
organic chemical wastes, and animal and clinical wastes.
• Co-incineration. Co-incineration has the benefit that plants are already capable of
accepting hazardous waste. Within the context of the current consultation on the
Substitute Fuel Protocol (SFP), the cement and lime industries are keen to increase
the numbers of alternative fuels in kilns. Currently cement kilns in the UK burn
waste oil.
6.73. The processes outlined above are possible options for the future treatment of hazardous
waste, and are likely to become part of hazardous waste management schemes in the
short to medium term. The major concern for hazardous waste producers at present is
short term hazardous waste management. However, it has been suggested that many
producers, especially at the SME level, remain unaware of the new regulations and their
potential impact. This is partly because their customers, i.e. the waste management
companies, have not informed them of the potential changes in disposal routes and
costs because they themselves do not yet know what they will be required to do since
the regulations and guidance have yet to be published. With the requirement for
treatment prior to landfill, and the lack of treatment facilities, there will be a surplus of
hazardous waste which presently cannot be treated. As previously highlighted, this
surplus may well build year on year until enough capacity is developed specifically for
the treatment of hazardous waste.
6.74. There are some concerns that amongst the confusion and the lack of legal routes for
disposal, criminals could thrive, and illegal handling and fly tipping could become more
common.
6.75. Short term plans have been discussed by the Environment Agency and other
organisations, with the following possibilities having been identified:
• Stockpile wastes on-site until the treatment facilities are available. However many
producers will not have sufficient area to stockpile their hazardous wastes, especially
for up to 5 years, and stockpiling for a significant period of time (e.g. over one
year) is not permissible without a waste management licence.
• Permit some warehouse premises for central stockpiling of hazardous wastes.
However, this is unlikely to happen by the 16 th July 2004 and is unlikely to be costeffective
for large volume wastes such as contaminated soils and effluents; and is
not necessarily practical for many waste streams unless they are drummed or
otherwise contained.
• Licensing of hazardous cells to take excess waste (none licensed to date).
• Export waste for recovery.
• Leave wastes (in particular contaminated soils) where they are. DEFRA suggest that
brownfield development should be put on hold until the problems of treatment
capacities have been solved. This is unrealistic, especially for the medium to longterm.
• Relax the co-incineration rules (however this is not acceptable within EU legislation)
114

6.76. As can be seen from the above, there are only limited options at present to manage the
expected shortfall in treatment capacity for hazardous wastes after 16 th July 2004 and
an interim solution has yet to be fully defined. In the short-term, it may be expected
that prices of hazardous waste disposal will rise considerably due to increased transport
distance.
Recommendation 55: It is recommended that urgent consideration should be given to
measures to address this situation in the short to medium term. Such
measures may include:
• An awareness raising campaign for London’s hazardous waste producers,
particularly focused on SMEs (refer also to recommendations on C&I
wastes).
• Supporting contaminated land treatment technologies focusing on
assessing and promoting those most appropriate to London. This may
include information dissemination, showcasing technologies, assessment of
technology used overseas, assessment of the technical requirements for
London, set-up of one or more major interim treatment sites within easy
reach of London (such as on former landfill sites), and consideration of
ways to support development that incorporates on-site treatment methods.
• Supporting interim storage solutions for easily handled low volume,
packaged hazardous wastes.
6.77. With regarded to contaminated land arisings, if treatment can be promoted whether onsite
or on specially set-up facilities within London (such as former landfill sites), this not
only has the potential to address the treatment and disposal issues to a significant
extent, but it would also greatly help to increase the self-sufficiency of the management
of London’s hazardous wastes.
Recommendation 56: Due to the short timescale until transposition of the Hazardous
Waste Regulations, it is recommended that developing a strategy for the
treatment of London’s hazardous wastes should be accorded a very high
priority.
6.78. The potential for waste minimisation to play a part in reducing the total arisings of
hazardous wastes was discussed at the recent Hazardous Waste Conference in London 42 .
It was noted that a considerable amount had already been achieved in this area and that
whilst further reductions were possible, they were considered to be unlikely to achieve a
considerable impact on total arisings. It was also noted that there may well have been a
tendency to over-classify wastes as ‘hazardous’ in the past, perhaps due to a lack of
understanding of the regulations or the inclusion of packaging, etc. due to poor waste
segregating. It was expected that increased treatment and disposal costs would force
companies to look more closely at over-classification and that this may be an area where
some future advances could be made in waste minimisation.
Growth in Hazardous Wastes
6.79. Past hazardous waste arisings indicate that the major categories of hazardous waste
production in London are from two EWC categories, ‘C&D and asbestos’, and ‘oil &
oil/water mixtures’. It is likely that these two waste streams will remain a major
proportion of hazardous waste production for the forseeable future.
42 letsrecycle.com Conference, Hazardous Waste Summit, 24 th March 2004
115

6.80. However, the new hazardous waste classification system relating to the Hazardous
Waste Regulations and the European Waste Catalogue will increase the numbers of
wastes classified as hazardous. It is estimated that an additional 250 waste types will be
classed as hazardous. An area of growth in the future production of hazardous waste in
London is likely to be the classification of waste electric and electrical equipment
(WEEE) as a hazardous waste. This could hold significant implications for the UK as a
whole, including London. Nevertheless, it is possible that the relatively high-technology
re-processing facilities required to reprocess such waste could be located in or near to
London, thereby helping to increase London’s self-sufficiency in hazardous waste
management.
Recommendation 57: As part of London’s drive towards self-sufficiency in waste
management, it is recommended that ways to encourage the development of a
hazardous waste processing industry should be explored, particularly for the
‘new’ hazardous wastes that will result from the implementation of the
hazardous waste regulations in mid-2005. It is recommended that a strategy is
developed to mimimise and prevent illegal waste management activities in
London resulting from the advent of the new Hazardous Waste Regulations.
6.81. With the changes in hazardous waste regulations, a variety of electronic and electrical
equipment will be classed as hazardous. Wastes will be included as hazardous wastes
because they are listed in the Hazardous Waste Regulations due to their components
(the majority of WEEE), because they are listed specifically, or because they are above
the contaminant threshold limit.
6.82. According to a presentation by Graham Davy of the SIMS Group (Hazardous Waste
Summit, 24 th March 2004), fridges, televisions and monitors, and fluorescent tubes will
definitely be classed as hazardous due to the content of CFC, lead and mercury
respectively. There is also the possibility of washing machines (cables and piping) and
vacuum cleaners also being included. In the London area this will create a huge amount
of additional hazardous waste – from domestic, commercial and industrial sources.
6.83. SIMS Group highlighted the fact that even though objects may be classed as hazardous
on the list, the amount of hazardous substances may not meet the threshold level for
hazardous wastes. Fluorescent tubes appear on the hazardous waste list, however the
percentage of mercury does not exceed the hazardous threshold. Therefore, if they
were not directly named as hazardous, they would not be considered hazardous on
account of their mercury content. Thus there remains some uncertainty about what will
actually be deemed to be hazardous under the new regulations.
6.84. As outlined in Annex II of the WEEE Directive, certain items must be ‘removed’ from
WEEE. Some items appear on the Hazardous List as an absolute, for example batteries.
However, other components which are not listed may make the item hazardous. The
term ‘remove’ has not yet been fully defined. Removing fluorescent tubes or batteries
can be easily managed before any further treatment. However, if the term ‘remove’
includes removing button cells or small printed circuit boards, the process becomes
much more complex. This could provide problems with equipment such as washing
machines where components needing to be removed are less than 0.5% of the total
product weight.
6.85. A DEFRA sponsored WEEE and Hazardous Waste Report is due imminently; hopefully
this report will outline the requirements of WEEE in terms of hazardous waste. With
116

clearer guidance on WEEE, it will be possible to suggest the likely implications these
changes will have on London specifically.
Options for Specific Measures
6.86. The increasing complexity of the hazardous waste industry and the management of
hazardous materials, in addition to the urgent need for treatment facilities to ensure
compliance with the EC Directives, is expected to raise the costs of managing hazardous
waste. The increase in costs may promote waste minimisation; however it may also
generate an increase in illegal handling of wastes and fly tipping, in the short term.
6.87. It appears that many producers are unfamiliar, or unaware of the effects that the change
in the hazardous waste regulations and the effect that hazardous waste classification
may have. Businesses have a legal duty of care to ensure they pass their waste to a
legitimate waste carrier. If their waste is fly tipped, then they could be prosecuted. It is
important that awareness is raised, especially amongst the numerous small and medium
sized enterprises (SMEs) in London (refer Chapter 4 for an overview of London’s
670,000 SME’s). All producers of hazardous waste must be made aware of the future
changes to legislation, and the fact that many more businesses will be considered to be
producers of hazardous waste under the revised EWC.
Recommendation 58: It is recommended that steps are taken to better inform all
waste producers - including the large community of SME’s in London - about
their statutory responsibilities with respect to ‘controlled waste’ in general,
and ‘hazardous waste’ in particular.
6.88. In terms of developing a specific approach for London, it is likely that the three major
sources of hazardous waste arisings in London in the forseeable future, which require
management and treatment are:
• Construction and Demolition Waste and Asbestos.
• Oil and Oil/Water mixtures.
• Waste Electronic and Electrical Equipment.
6.89. Since the largest group of hazardous waste arisings in London at present is construction
and demolition and asbestos waste, and from July 2004, there are unlikely to be any
disposal options within 75 miles of London, a key element of any strategy should be an
initiative to develop ways to manage this waste within London. Since the majority of
this waste stream comprises contaminated soils, the promotion of in-situ treatment and
on-site ex-situ treatment has the potential to significantly reduce waste movements and
disposal. Although such treatments are not favoured in the UK at present, they may be
the only sustainable and viable approach in the future. Alternatively, a number of
centralised facilities within London (e.g. at former landfill sites) that are capable of
accepting these wastes for processing could be established. Minimising the movement
of spoil from contaminated land would contribute to resolving a major problem in
London after July 2004.
Recommendation 59: It is recommended that a strategy is developed to manage
contaminated soil from construction and demolition works in London, as a
matter of urgency.
117

6.90. The future treatment of asbestos arisings from London is less urgent since it is a more
stable waste form with fewer treatment requirements. A permit has recently been
granted for the Pinden Quarry landfill in Dartford, for the acceptance of asbestos only.
6.91. Oil and oil/water mixtures are often used as fuel in the co-incineration process and the
use of such facilities is a key component in the management of hazardous wastes.
Reprocessors and operators currently consider that the Substitute Fuels Protocol is
preventing them from handling more of this kind of waste. Future changes to the
protocol may increase the opportunities for co-incineration at cement and lime kilns to
handle more hazardous waste. Responses to the consultation paper ‘Proposals to
Revise the Substitute Fuels Protocol for use in Cement and Lime Kilns’ are due by the
18 th June 2004.
6.92. Waste Electronic and Electrical Equipment (WEEE) is likely to be a significant element of
the hazardous waste produced in the future. The outcome of the DEFRA report on
WEEE and Hazardous Wastes will pave the way for requirements for handling WEEE in
London and the likely facilities required. The key areas for handling WEEE would
involve the re-use, recovery and recycling of materials. This could be promoted by the
GLA, with the help of networks of business and groups dealing with WEEE. Two sites in
the UK (Manchester and Long Marston) are currently being used to carry out a range of
trials into the best methods of disassembly, material separation and recovery of WEEE.
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7. Findings and Recommendations
7.1. The key findings of the study are summarised in this chapter. A complete list of the
study findings is presented from paragraph 7.17-7.58, for each of the C&I, C&D and
hazardous waste sections. However, an overview of the key findings and themes is first
presented in paragraphs 7.3-7.16.
Overview of Key Findings
7.2. The key findings from the research into current waste management arrangements for
Wider Wastes can broadly be summarised under the following headings:
Data Sources and Reliability
7.3. The study has highlighted the limitations associated with the existing available data on
London’s wider (non-municipal) wastes. While the Environment Agency’s consignment
note system provides a reasonably comprehensive record of hazardous waste arisings,
the current data for commercial and industrial (C&I) and construction and demolition
(C&D) waste is based on extrapolations from limited national survey data. Significant
data uncertainties exist from the limitations of these surveys in terms of (a) their size
and how representative they are of the actual waste streams and (b) the applicability of
the national data surveys (which include only limited survey data from London) to
London’s waste. As a result, the existing waste data about London’s C&I and C&D waste
streams should be regarded as estimates only, rather than absolute figures and subject
to significant uncertainty.
7.4. This uncertainty also extends to the composition of these wider waste streams. While
the composition data on hazardous waste is considered to be detailed and reliable, the
composition data for the other waste streams suffers from the following inadequacies:
• C&I wastes: Only limited composition data is available on a sectoral basis,
particularly for London as a whole with very limited data available on specific
industrial sectors.
• C&D wastes: Very few surveys have been carried out on C&D waste composition in
the UK; none of these have been carried out in London. There is evidence that the
composition of demolition waste is quite different from construction waste and also
that the waste composition profile changes depending on the stage of the
construction project.
7.5. London’s C&I wastes are currently estimated (from a survey based on 1998/1999 data)
as 7.1 million tonnes, of which 61% are reported from commercial sources (and
therefore similar in composition to municipal wastes) and 39% from industrial sources.
The results from a new survey (currently being undertaken by the Environment Agency)
are expected in the autumn of 2004 and are quite likely to be significantly different
from this earlier estimate, in terms of both the estimate of total waste arisings and the
split between commercial and industrial sources.
7.6. London’s C&D wastes are currently estimated (from a national survey of 2002 arisings)
to be in the range 3.70-8.40 million tonnes per annum. This estimate comprises ‘hard’
C&D wastes only and excludes ‘soft’ C&D wastes such as timber, plastics, plasterboard
etc. The quantity of these ‘soft’ waste arisings is currently not measured. As a result,
the above range probably represents an underestimate of London’s total C&D waste
arisings.
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7.7. London’s total hazardous waste arisings in 2002 were recorded by the Environment
Agency’s consignment note system as 458,579 tonnes.
Current Practice and Recycling / Recovery Levels
7.8. The current levels of recycling and recovery of London’s wider wastes vary according to
waste category. Relatively high levels of recycling and recovery are reported for
London’s ‘hard’ C&D wastes (72%), much higher than the average for England (41%)
for this waste stream. However these rates may reduce when considering the C&D
waste stream as a whole, as defined in the European Waste Catalogue 2002 (including
‘soft’ C&D wastes). The bulk of the recycling and recovery is reported as crushing of
hard materials for re-use as bulk or engineering fill. There is little evidence of ‘higher
value’ recycling being carried out, e.g. production of aggregate for concrete from
secondary materials.
7.9. In contrast, relatively low levels of recycling and recovery were reported from London’s
C&I and hazardous waste streams. London’s C&I wastes are typically collected, bulked
up and transported to landfill out of London or for incineration. Currently, significantly
more than half of London’s C&I wastes (65-70%) are landfilled. Similarly around 73%
of London’s total hazardous waste production in 2002 was sent for disposal to landfill,
mostly outside London.
Waste Transportation
7.10. While there is some evidence that the River Thames and London’s rail network are
increasingly used for waste transportation purposes, the current arrangements are
predominantly for municipal waste. Significant additional available capacity for waste
transportation is reported by the Port of London Authority (for the River Thames) and
by British Waterways (for the narrow canals and River Lee). However a key constraint
for the future expansion of waste transportation by water is the availability of waterside
land with planning permission for waste transfer facilities, partly due to the competition
for new house-building sites.
Existing and Future Infrastructure
7.11. It is clear from this study that London currently lacks the necessary infrastructure to
enable it to manage its wider wastes in an increasingly self-sufficient and sustainable
way. The lack of the necessary infrastructure is particularly apparent for the processing
and disposal of hazardous wastes; however infrastructure deficiencies are also apparent
for higher value recycling / reprocessing of C&D wastes, and also for C&I wastes.
7.12. In the short-term, the critical issue is the expected complete absence of any hazardous
waste disposal facilities within London from July 2004, as a consequence of the
implementation of the Landfill Directive requirements. This will result in all hazardous
wastes (including contaminated soils from brownfield development) being transported
to a small number of landfills significant distances outside of London. This has
potentially serious consequences for London’s brownfield development programme,
resulting from the likely increased costs and construction delays associated with site
preparation and clean-up.
7.13. For the medium-longer term, the results from the study consultations indicate that
recycling and reprocessing activity is likely to increase within the waste management
companies and the reprocessing sectors, with a resulting increase in the infrastructure
capacity. However, the drivers for such development are purely economic and the
constraints on site development within London (i.e. land availability, planning consent
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and cost) are likely to result in delays for any new infrastructure coming on-line, with
much of it being located outside of London.
Waste Producers and Behaviour
7.14. The study identified a number of key findings with respect to non-municipal waste
producers (ie. commercial and industrial companies) and their behaviour. The vast
majority (>99%) of such companies in London are small and medium enterprises (SMEs)
which account for 46% of employment in the commercial sector and 20% of
employment in the smaller industrial sector. While the environmental performance of
the larger or well-known industrial companies is often driven by corporate image,
consumer pressure, legislation (e.g. PPC permitting requirements) and environmental
reporting and management requirements, there are far fewer drivers on SME’s to move
them towards more sustainable waste management practice. Possible routes to
encourage changes in SME practices include (a) the Government’s Envirowise
programme to assist businesses, and (b) supply-chain management pressure from larger
companies with well-developed environmental management systems in place.
7.15. A best practice Demolition Protocol has been developed jointly by the ICE and CIWEM,
using funding from WRAP. This has the key aim of encouraging the planning system to
require more efficient use of resources in demolition and construction projects. To date
the protocol has been adopted by at least three London boroughs in the form of
relevant planning policies or guidance.
7.16. While a number of waste exchanges currently operate in London for C&I and C&D
waste, these do not appear to be widely used, other than by small companies.
Summary of Key Findings for C&I Wastes
Findings on Waste Arisings, Disposals and Composition
7.17. The main reference source for the tonnages and composition of commercial and
industrial wastes for London is the SWMAL 200043 report, which was compiled by the
Environment Agency from national survey data on municipal, C&I, C&D and hazardous
waste. This estimates that 7.1 million tonnes of C&I wastes were produced in London in
1998/99, of which 4.35 million tonnes (61%) were estimated to be derived from
commercial activities, and 2.74 million tonnes (39%) from industrial sources. The
SWMAL also reports that 84% of the C&I waste arisings were exported out of London
for recovery or disposal. The Environment Agency’s Local Waste Interrogator database is
an on-line application designed to help local authorities extract waste input and
capacity data for their own areas. This is based on site-return data but only provides
details of the amount of waste deposited in and around London but not on the
quantities generated. However, for future purposes, this may be a useful tool to track
deposits in London itself.
7.18. The SWMAL 2000 data is based on extrapolations from national and regional survey
data. Of the 20,000 companies approached for data across the UK, 18,600 provided
responses, including around 1,200 from within London. The C&I figures reported in the
SWMAL are therefore estimates only, based on data that is almost 6 years old and
should be regarded with caution as the actual figures could be significantly different
from these. The EA is currently carrying out an updated survey (using a smaller number
of questionnaires) and the results of this are expected to be published in the autumn of
2004.
43 Strategic Waste Management Assessment, London, 2000, Environment Agency.
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7.19. There is only limited compositional data on C&I wastes (based on 14 Standard Industry
Code groupings). This indicates that more than 60% of the C&I waste arisings in
London are generated by activities such as administration, retail hotels, education etc.
that produce wastes similar in composition to municipal wastes. In this regard there may
be the potential for a greater degree of integration between the Mayor’s municipal
waste strategy and that for wider wastes. In particular, the types of waste management
facilities developed to process municipal wastes would also be suitable for processing
these commercial and industrial waste arisings.
7.20. Our evaluation of the available compositional data on commercial wastes suggests that
some 75% (i.e. 2.6 million tonnes/annum) is likely to be potentially recyclable. Of the
potential recyclables, 50% is estimated to be paper (1.3 million tonnes) and 20%
cardboard (530,000 tonnes), 14% glass (370,000 tonnes), 11% putrescible (284,000
tonnes) and 4% plastic (93,000 tonnes). It should be noted that a higher amount of the
plastic wastes are considered to be non-recyclable (222,000 tonnes).
Findings from Consultations with Waste Management Companies
7.21. There are a wide range of waste management companies operating in London, some
with transfer stations and materials recovery facilities within London. These companies
typically collect, bulk up and transport C&I wastes for disposal to landfill outside of
London, or for incineration. The responses to the consultation process indicated that
while some recycling of C&I wastes is carried out, the bulk of C&I wastes (estimated as
65%-70%) is landfilled and that London currently lacks the recycling capacity and
markets necessary to stimulate recycling of C&I wastes, particularly for paper,
cardboard, timber, plastics.
7.22. All the waste management companies with whom we had detailed discussions operate
formal environmental management systems (EMS) or are in the process of developing
them. Compliance with ISO14001 is a useful tool to encourage supply chain
management.
7.23. Our consultations with the reprocessing industry that serves the London region
identified an increasing range of activities in London being carried out by both
national/regional reprocessors and local London companies. However coverage is
currently patchy – both geographically and by material type - and there remains a lack
of information available to waste producers about the recycling / reprocessing routes
that exist. Both WRAP and London Remade are developing initiatives that are designed
to stimulate reprocessing/recycling markets in London. A study carried out on behalf of
the London Development Agency by Brook Lyndhurst consultants (2002) identified a
series of barriers facing the London waste reprocessing sector, as well as primary
development opportunities. The key ones were WEEE (waste electrical and electronic
equipment) and ELVs, (end of life vehicles), while materials-specific ones included
plastics, glass, paper and wood.
Findings on Water and Rail Transportation
7.24. The Port of London Authority report that the River Thames is currently used to
transport around 800,000 tonnes per annum of municipal waste, where containerised
wastes are loaded onto barges at four waste transfer stations and shipped to two waste
transfer stations in Essex for offloading for landfill disposal at Cory’s Mucking Landfill
and Cleanaway’s Rainham landfill. The Authority also indicated that the river has
significant additional capacity for waste transportation but that this is currently
constrained by the capacity of their existing riverside transfer stations and that they are
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seeking to establish another three waste transfer stations to provide additional access to
the river for the transportation of waste. One waste management company is
considering using barge transport, instead of using road links, for transferring dry
recyclable material to their MRF in Kent.
7.25. British Waterways are actively promoting the use of the broad and narrow canals and
the River Lee in London for the transport of freight, with particular emphasis on wastes.
A pilot study is currently being carried out on the River Lee by Waste-by-Water Limited
using a Government grant, and if successful, is expected to lead to increasing use of the
river for municipal waste transport. The major limitations to increasing canal transport
are considered to be the lack of wharf sites (partly due to canal-side housing
developments), and the lack of encouragement of waste transport by canal within
current planning policy and guidance. Also the current rules applying to the Freight
Facility Grant system are reported to present a significant limitation to the development
of the necessary loading / unloading infrastructure, and British Waterways are currently
lobbying the Government to have these amended. British Waterways also commented
that a requirement for new projects to consider waste transport at the ’front-end’ of the
planning and design process would help promote waste transport by canal, and it is
understood that consideration is being given to this in the current planning review being
undertaken by the ODPM.
7.26. Rail transport offers a cost effective means of transportation of wastes. Rail is suitable
for high volumes of all waste materials, including industrial and commercial wastes.
Trains have a larger capacity than road haulage vehicles and offer a more economical
mode of transporting over long distances. The West London Waste Authority has
successfully transported wastes by rail since 1977, and currently use this form of
transport for up to 75% of the total wastes sent for disposal. Wastes are transported
from Hillingdon rail transfer station to the Shanks landfill site at Calvert on a nightly
basis. The North London Waste Authority also receive a daily rail transport service from
the transfer station at Hendon to Stewartby landfill site, also operated by Shanks. This
service, from Hendon to the landfill site and back, removes 192 long-distance lorries
from the roads each day, thus reducing congestion and pollution from haulage vehicles.
It is understood that similar arrangements are about to commence in East London
through a long-term waste disposal contract with Shanks.
Findings with regard to Waste Producers
7.27. The vast majority (99.8%) of companies in London are small and medium sized
enterprises (SMEs), and they account for just under half of London’s total employment
and turnover. In the commercial sector, SMEs provide 46% of total employment, while
in the industrial sector SMEs provide 20% of all employment – although this is much
less in real terms due to the smaller scale of industrial activity in London, compared with
the commercial sector (i.e. 258,000 compared to 800,000).
7.28. While the environmental performance of the larger industrial waste producers is largely
driven by legislation (e.g. PPC), environmental management systems (EMS), corporate
image, and environmental reporting requirements, for the majority of companies in the
service sector there are no legislative drivers to reduce waste. Further, the contribution
that waste management costs make to the office-based sectors (which predominate in
London) are relatively insignificant and hence less of a stimulus for action.
7.29. Although the SME community represents a significant proportion of commercial and
industrial activity in London, it is highly-fragmented and not necessarily focussed on
good environmental performance. Often SME managers are poorly informed about their
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waste management obligations and best practice and are uncertain about where to seek
advice.
7.30. The Government’s Envirowise programme is designed to specifically assist business with
environmental performance (including waste management). While it is recognised that
the Envirowise programme in its current format may not provide the required level of
detailed, sector-specific, waste management information that is necessary to inform
waste producers on waste management best practice, it nevertheless provides an
existing infrastructure by which advice and support may be provided to waste producers
across many commercial and industrial sectors. The future of the Envirowise programme
is currently in doubt but it would present a missed opportunity to inform producer
behaviour if it was to close.
7.31. A total of 123 companies (or sites) are certified to ISO 14001 within London. In some
cases, EMS can also be usefully applied to SMEs to improve environmental performance,
although in many instances EMS (and ISO 14001 in particular) is inappropriate for
smaller sized companies. Alternatively, SME performance can be influenced through
supply-chain management under an EMS system.
Main Findings from Local Authority Consultations
7.32. Questionnaires were sent out to each of London’s 37 waste collection, unitary and
disposal authorities to obtain data about their collection and disposal arrangements for
commercial and industrial wastes; responses were received from a total of 22 authorities
(a response rate of 60%). The key findings from this survey were:
• The majority of the collection authorities collect commercial and industrial wastes
mixed with the household waste collections, with just a few collecting separately.
This raises questions on the validity of domestic waste reporting. Around half of the
respondents do not offer a collection service for industrial waste
• Only a few collection authorities offer a collection service for commercial recyclables
(e.g. glass from pubs and clubs)
• Collection services are provided by both DSOs (direct service organisations) and
commercial companies.
• The majority of collection authorities do not have separate data about the C&I waste
that they collect. Only one authority currently analyses C&I waste arisings by
customer type and composition and while several authorities could undertake this
analyses, they do not currently do so.
Summary of Key Findings for C&D Wastes
7.33. The data on construction and demolition wastes from the Symonds Group national
surveys (2000, 2002) are estimates only of the total arisings of ‘hard’ and ‘excavated’
construction and demolition wastes. The survey results specifically exclude ‘soft’
construction and demolition waste such as timber, plastics, metals and other packaging
materials. The results from the 2002 survey indicate the quantity of ‘hard and
excavated’ construction waste arisings in London to be in the range 3.70 – 8.40 million
tonnes, with a reported confidence level of 90%. It is not prudent to assume that the
real figure will necessarily lie close to the centre of this range (i.e. 6.05 million tonnes),
or indeed that it will definitely lie within this band at all.
7.34. Given the exclusion of the ‘soft’ construction and demolition wastes from the Symonds
surveys, and that these wastes are not accounted for in any other surveys, the Symonds
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surveys most likely represent an underestimate of the total arisings of construction and
demolition wastes, as defined in the EWC 2002.
7.35. There is a lack of comprehensive and reliable data on the composition of construction
and demolition waste in the UK generally, including London. Some composition survey
data does exist, but the sample sizes are small, poorly defined and not necessarily
relevant to the construction and demolition wastes generated in London. Nevertheless
the available data suggests that it may be misleading to assign an average composition
to construction and demolition waste generally. This is because (a) the separate
construction and demolition waste streams are quite different (with demolition wastes
being predominantly inert, and construction wastes being high in packaging waste) and
(b) the composition of the waste streams also appears to vary depending on the stage
of development of the project to which they relate.
7.36. The Symonds survey data indicates that the level of recycling of ‘hard and excavated’
construction and demolition waste in London (72%), for example for use as bulk fill, is
significantly higher than the average for England (41%). Transportation data from the
Symonds survey also indicates that materials for recycling are typically not hauled more
than 25kms (15 miles) from the point of arising, suggesting that much of this recycling
activity is carried out in or around London. Our consultations with industry indicates
that currently the bulk of this recycling activity is simply comprised of crushing for reuse
as low grade bulk fill, with little evidence of ‘higher value’ recycling being carried
out. However some consultees reported that the economic conditions are becoming
more favourable for higher value recycling and that this is increasingly being considered
by some contractors, not just for the ‘hard’ wastes but also for the ‘soft’ wastes.
7.37. Our survey indicated that in London there are currently a total of 237 facilities for
dealing with construction and demolition wastes. This includes 32 mobile crushing and
screening plants, 32 fixed crushing and screening plants, and 28 materials recovery
facilities. Also included in this figure are 10 landfills and 116 exempt sites. There was a
general view amongst consultees that the availability of recycling facilities in London
was satisfactory for general wastes (concrete, bricks etc) but less so for specialist wastes
(plastics, timber, glass etc). It was also suggested that the existing facilities for
recycling concrete and bricks are fully utilised.
7.38. There is considerable concern among Contractors about the impacts on the construction
industry of the Landfill Directive which will put a stop to the co-disposal of hazardous
and non-hazardous waste in July 2004. The view was also expressed that the traditional
UK approach to contaminated land remediation, i.e. excavation and disposal of
contaminated soils and asbestos to landfill, is likely to continue with the extra transport
costs being passed onto the developer.
7.39. A best practice Demolition Protocol has been developed, using funding from WRAP.
This has the key aim of encouraging the planning system to require more efficient use
of resources in demolition contracts and new building work. It is reported that at least
three London boroughs are in the process of adopting some or all of the Demolition
Protocol requirements in the form of relevant planning policies or Supplementary
Planning Guidance.
7.40. A range of ‘waste exchange’ type tools have been developed by various organisations to
assist in the efficient use of materials from the construction and demolition industries.
These include the Aggregates Information Service set up by WRAP. However our
consultations have indicated that the rate of use of these tools by the major
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construction and demolition companies is low and it may be that the tools are of more
use to small scale operators in niche markets (e.g. fireplaces, interior doors etc.)
7.41. The private developer is rarely a driving force for sustainable waste management in
demolition and construction contracts and that, whilst public sector contracts may
encourage this to an extent, the ability of the market to absorb the additional costs is
limited. Nevertheless, the increasing costs of landfill provide a real economic incentive
for the recycling of construction and demolition wastes. This appears to have had a
beneficial effect on the industry over many years and is likely to continue to do so in to
the future.
7.42. The London Sustainable Construction Project is developing a Code of Practice for
sustainable practices throughout the whole life cycle of construction. The Code is
aimed at all parties involved at each stage of the construction process, e.g. funders,
planners, designers, contractors. The Code will suggest performance specifications and
targets for good performance and will be backed up by an implementation guide. The
Demolition Protocol will form part of this best practice. The scoping stage of the
London Sustainable Construction Project has recently been completed and funders are
being sought for the next (development) stage.
7.43. Our consultations indicated that while many contractors were interested in waste
minimisation and recycling, in some instances their recycling efforts had been hampered
by waste management licensing requirements. Others suggested that any association
between construction and the use of ‘waste’ materials can put off potential purchasers.
This suggests a need for education of operators in this sector on best practice to
maximise the opportunities for waste minimisation and recycling.
7.44. Denmark, the Netherlands, Germany and Belgium are the leading European countries in
terms of percentage recycling of C&D waste. This is achieved through policy, legislative
and other measures including inter alia: restrictions or bans on disposal of C&D waste in
landfills; subsidies for recycling; voluntary agreements between authorities, the C&D
industry and recycling organisations; demolition plans; advisory services; good
monitoring and reporting systems; and the establishment of standards, certification and
quality assurance schemes.
Summary of Key Findings for Hazardous Wastes
7.45. The Environment Agency currently provides the most accurate and detailed source of
data on hazardous waste, with the source of the data being the consignment note
system which generates input data for their Special Waste Tracking system (SWaT) and
web-based Hazardous Waste Interrogator. A detailed breakdown of data is available for
1999, 2000 and 2001, with only total figures for 2002.
7.46. However there are some uncertainties about the data validity from the EA’s system since
the consignment note system was not designed to take account of the complexities
arising from multi-stage hazardous waste movements, and the processing of hazardous
wastes on the site of production. The Environment Agency also operates a separate
database to record the hazardous wastes processed on the site of origin; however this
data is commercially sensitive and is therefore confidential.
7.47. In preparation for the introduction of the new Hazardous Waste Regulations (expected
in mid-2005), the Environment Agency is planning to introduce a revised hazardous
waste recording and reporting system that meets the requirements of the new
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egulations and also seeks to minimise the opportunities for data under and overreporting
that are present in the current system.
7.48. The Environment Agency believes that any data validity uncertainties associated with
their current SWaT database are not significant compared with the potential for the
over-reporting of hazardous wastes resulting from the current common practice of
notification of mixtures of non-hazardous and hazardous wastes as all hazardous.
7.49. In 2002, a total of 458,579 tonnes of hazardous waste arisings were recorded from
London. This represents around 9% of the total hazardous waste arisings recorded in
England and Wales (5.08 million tonnes). The bulk of London’s hazardous waste
arisings (334,558 tonnes, 73%) are ‘C&D waste and Asbestos’. Other significant waste
categories reported are: ‘Oil and Oil/Water Mixtures’ (38,085 tonnes, 8%), Water
Industry and Waste Water Treatment (33,198 tonnes, 7%) and inorganic chemical
processes (9,974 tonnes, 2%).
7.50. Of the 334,558 tonnes of hazardous ‘C&D waste and asbestos’ arisings in London in
2002, analysis of previous years’ data indicates that the greater part (around 68%, or
227,500 tonnes) is likely to comprise contaminated soil materials from brownfield site
development.
7.51. London is the least self-contained region in England and Wales for hazardous waste
management and in 2002 it treated and disposed of only 3.7% (16,900 tonnes) of the
hazardous waste it produces. The bulk of the hazardous waste exported from London
was landfilled. Conversely London also imports hazardous waste from other regions and
in 2002 this amounted to 18,700 tonnes, mostly from the South-East and the East of
England. An analysis of the types of hazardous waste imported into London for
treatment and disposal indicated the bulk of these wastes (10,127 tonnes) comprise ‘oil
and oil/water mixtures’.
7.52. An estimated total of 334,045 tonnes (~73% of London’s total hazardous waste
production) was landfilled in 2002, most of this outside London. It is likely that the
majority of this was untreated.
7.53. A breakdown of hazardous waste disposed of in London (including imports) indicates
the two main categories to be: ‘oil and oil/water mixtures’ (40%, 22,376 tonnes) and
‘C&D waste and asbestos’ (35%, 19,604 tonnes). However our review of infrastructure
capacity in London indicates that from July 2004, there will be no capacity in London to
accept C&D wastes and asbestos, and these wastes will have to be disposed of outside
London. Oil and oil/water mixtures will most likely continue to be processed in London.
The requirement from July 2004 to export all hazardous C&D wastes (mostly
contaminated soils) is likely to have an immediate impact on the cost of brownfield site
development in London - from this date.
7.54. Overall there has been no growth recorded in hazardous wastes arisings in England and
Wales between 1998/99 and 2002/03, and this trend has been repeated in London,
although the pattern of arisings documented in London over the last 4 years is rather
erratic with annual fluctuations of up to 45%. It is uncertain whether these fluctuations
are representative of changes in actual waste arisings or a function of the data validity
and consignment note reporting uncertainties.
7.55. For England and Wales, the effects of the Landfill Directive’s requirements to end codisposal,
and to pre-treat all wastes prior to landfill are expected to result in an annual
shortfall of some 1.0 million tonnes of landfill capacity from 16th July 2004. However
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the precise amount of landfill capacity that will be available nationally for hazardous
waste from this date is also not certain, since the permitting process for potential
landfills is not yet complete. It is quite possible that the process of permitting will not
be completed for all the available sites until shortly before the July 2004 deadline for
the end of co-disposal. It is the view of much of the waste management industry that
the use of separate cells for treated hazardous waste that is subsequently rendered nonhazardous
at non-hazardous landfills will not make up a significant amount of the
estimated shortfall in the short to medium term.
7.56. After implementation of the new regulations, there will be no hazardous waste landfills
in London. The latest permitting data indicates that the closest landfills for London’s
hazardous waste are likely to be: Pinden Quarry, Dartford (asbestos only); Warboys,
Huntingdon, Cambridgeshire (approx. 76 miles from London); Kingscliffe, Northants
(approx 90 miles from London). London currently landfills in excess of 330,000 tonnes
of hazardous waste annually and a disposal route must be found for this material from
July 2004.
7.57. Research undertaken by the Hazardous Waste Forum and Environment Agency
estimates the quantity of ‘new’ hazardous wastes resulting (from expansion of the
definition of hazardous wastes under the Hazardous Waste Regulations) to be in the
order of 0.8 million tonnes nationally. London’s share of this is not known but is likely
to be in the region of 100,000 tonnes. These new hazardous wastes will comprise a
range of materials not previously defined as ‘special’ waste under the Special Waste
Regulations 1996 and will capture an additional 250 categories of materials, including
computers, fluorescent tubes, and televisions. As this will put an added disposal cost
burden on SMEs, and there are few available disposal sites, this is likely to result in
increased incidences of fly-tipping.
7.58. London has an imminent disposal capacity shortfall of around 330,000 tonnes per
annum from July 2004 and this shortfall will increase in July 2005 by an additional
c.100,000 tonnes. Taking account of the timeframe required to deliver infrastructure
capacity, London has a likely disposal capacity shortfall of some 1.3 million tonnes (over
3 years), 2.2 million tonnes (over 5 years) and 3.0 million tonnes (over 7 years).
Recommendations and Future Actions
7.59. The recommendations arising from the study are listed below. The resulting actions to
be included as part of the development of the GLA’s ‘Wider Waste’ Strategy are listed in
Table 7.1. Each action is prioritised and the relevant parties responsible for the
implementation are identified.
Recommendations: Commercial and Industrial Wastes
R.1 It is recommended that the validity of the data on C&I waste in London provided by the
Environment Agency in the ‘Strategic Waste Management Assessment, London’
(SWMAL) 2000 is improved by carrying out further targeted surveys of selected waste
streams relevant to London. Preferably this should be achieved by the GLA approaching
the Environment Agency as a matter of urgency to establish whether their current
survey can be extended to cover these terms. Government should also be lobbied to
provide more resources to the Environment Agency to fund future surveys.
R.2 It is recommended that, wherever feasible, the joint use of waste collection vehicles and
management facilities to handle both municipal waste and commercial and industrial
waste should be encouraged in order to facilitate increased levels of recycling and to
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make the maximum use of fixed assets. However, due care and attention should be paid
to the data reporting requirements to ensure that municipal and non-municipal wastes
are treated separately.
R.3 In order to advance the promotion of sustainable waste management practice in
London, it is recommended that a best practice guide be issued relating to the
management of waste resulting from large-scale public events.
R.4 It is recommended that greater use is made of advertising and other public awarenessraising
techniques to reinforce the need for sustainable waste management practices in
relation to packaging and the use of recycled materials.
R.5 It is recommended that Transport for London should take the lead in promoting the
transport of waste by water wherever feasible, and to lobby Government to support the
use of the river and canal network for this purpose.
R.6 In order to facilitate the transport of waste by water, it is recommended that suitable
sites in London are reserved for such use in Waste Local Plans.
R.7 It is recommended that the GLA supports British Waterways in their efforts to get
Government to amend the regulations relating to the receipt of Freight Facility Grants
such that it should apply to transport by water (and by rail) even where there is no
alternative.
R.8 It is recommended that Government is lobbied to issue planning guidance to encourage
developers to consider the way in which waste generated by their proposals is to be
managed and transported, particularly by water, at the outset of the planning and
design process.
R.9 It is recommended that, subject to the views of NetRegs, a more detailed survey of
waste management practice of commercial SME’s in London be undertaken to augment
the recent results of the SME-nvironment survey 2003 carried out by NetRegs.
R.10 It is recommended that support is provided to local authorities to
advise SMEs about environmental (including waste-related) matters, as
the majority seek assistance from local authorities as their first port of
call.
R.11 It is recommended that an increase in funding is sought for the Waste and Resources
Action Programme (WRAP) to ensure that start-up assistance is available to as many
SME recycling and reprocessing businesses as possible.
R.12 SME participation in recycling should be promoted through measures that make it easy
and cheap to participate. These should include the targeting of clusters of
neighbouring businesses, and further investigation of mixed dry recyclables systems
which avoid the need for complete source separation by providing processing at a
central separation facility.
R.13 In order to provide further support and advice on sustainable waste management for
public sector and non-commercial organisations, it is recommended that consideration
should be given whether relevant information and assistance could be provided by
Government through or alongside Envirowise.
129

R.14 In order to more effectively target potential users in the future, it is recommended in
relation to London in particular that information on the size of companies contacting
Envirowise, and the nature of their enquiries, is compiled on a systematic basis.
R.15 It is recommended that Government is lobbied as a matter of urgency to ensure the
continued operation and expansion of Envirowise.
R.16 It is recommended that Government is lobbied to enable Envirowise to extend its
services simultaneously to all commercial businesses, including wholesale, hospitality
and, particularly, offices (including serviced office accommodation).
R.17 As cost is not a particularly significant driver, and is unlikely to be in the short term, for
SMEs in adopting sustainable waste management practices, it is recommended that the
effectiveness of other incentives be researched. This should include education and
methods to raise awareness of the environmental and social consequences of disposalbased
solutions.
R.18 It is recommended that a single point of advice on environmental issues in London
should be developed as a result of discussions between the GLA, the London
Development Agency, DEFRA, DTI Envirowise and other relevant bodies.
R.19 It is recommended that discussions be held with the Environment Agency with a view to
improving access to clear, consistent and accurate advice on waste matters. It is also
recommended that a single portal for environmental information of relevance to
businesses is set up by Government, along the lines of the Planning portal
(www.planningportal.gov.uk). Consideration should be given whether to develop a
single environmental, health and safety portal as these subjects are often overseen by
the same person or group within a business and the portal site may therefore encourage
greater awareness of the advice available.
R.20 It is recommended that encouragement should be given to harmonise business waste
management activities, and for future funding support to be directed to this end. The
aim should be for fewer, and properly resourced initiatives with a wider out-reach
promoting a consistent message.
R.21 In order to help to overcome the critical shortfall in investment in reprocessing facilities
in London that results from the lack of certainty of contracts for the supply of recyclable
business waste (as distinct from the availability of long-term MSW contracts), it is
recommended that the GLA – in conjunction with London ReMade and the LDA –
should investigate ways of encouraging large waste producers to enter into long-term
recycling contracts, for example as an extension of the Green Procurement Code, or by
underwriting supply contracts.
R.22 It is recommended that the feasibility of establishing medium/large scale biogas
facilities for the processing of London’s commercial organic waste should be
investigated, including the feasibility of using the biogas and heat from such facilities in
co-located industrial sites.
R.23 It is recommended that the prioritisation accorded by organisations such as WRAP, the
LDA and London Remade to particular waste streams for recycling and reprocessing
should be monitored to check whether London’s waste management needs are properly
represented. This information should be used to inform the Wider Waste Strategy which
should be clear about the priority waste streams to be addressed in London, with
reduction and recycling targets set for each.
130

R.24 Given the apparent success of the Mayor’s Green Procurement Code, it is recommended
that funding should be maintained subject to a series good performance targets.
R.25 It is recommended that the increased use of Environmental Management Systems (EMS)
should be promoted amongst London’s major companies and organisations, for example
through voluntary agreements with appropriate trade groups. This should apply both to
the commercial and the industrial sectors and should be made into a statutory
obligation for larger companies.
R.26 It should be recognised that the successful implementation of EMS for smaller
organisations is likely to require some form of support. Collaboration with the LDA
should continue into researching the promotion and provision of environmental
management advice and support. It is also recommended that the Institute of
Environmental Management and Assessment (IEMA) should be consulted in this regard
as they are actively involved in promoting BS 8885. Consultations should also be
undertaken with Envirowise with regard to the applicability of their existing services and
whether they are able to provide additional support to promote EMS in London. A
phased approach is recommended in which particular sizes of organisations in particular
sectors are targeted over forthcoming years.
R.27 It is recommended that environmental reporting by London’s major businesses and
public sector organisations should be strongly encouraged, and that guidance and/or
best practice references should be prepared, including the key performance indicators
that companies should be reporting on. This may usefully also encompass sector-wide
reporting in conjunction with trade associations, which should become statutory. The
promotion of a web-based approach, perhaps along the lines of capitalwastefacts.com,
may be an appropriate way of reporting headline indicators.
R.28 It is recommended that discussions be held with the Stock Exchange to explore the
possibilities of using their centralised database on the social and environmental
performance of companies as part of the Wider Waste Strategy.
R.29 It is recommended that discussions are held with relevant trade associations to see to
what extent their company members can be encouraged to adopt sustainable waste
management practices. It is suggested that contact is made with London Remade to
establish what means they have adopted to recruit companies onto their Green
Procurement Code. The next stage will then be to contact the Trade Association Forum
in order to determine a phased strategy of initiating contact with trade associations
directly. This could be based on SIC codes.
R.30 It is recommended that a targeted programme of compositional waste surveys should be
carried out in those commercial sectors in London where least information is available,
particularly the wholesale and education sectors. The aim of these surveys is to update
and expand the ‘City of Westminster Waste Analysis’ SWAP report of April 2001 such
that this type of information is available across the whole of London.
R.31 In the interim, before the results of the Environment Agency’s update of the Strategic
Waste Management Assessment, London (SWMAL) 2000 report are available, it is
recommended that a contingency of between 4-10% is made in estimating the amount
of waste generated by the C&I sector in order to take account of the growth of 7% in
employee numbers over the next two years, as forecast by the London Development
Agency. A range of 4-10% is put forward to cater for uncertainty relating to the growth
or decline of industrial activity in London over this period.
131

R32 It is recommended that a reduction in the use of paper, cardboard and plastics by the
commercial sector is targeted as a priority in the Wider Waste Strategy. Where paper,
cardboard and plastics are used, they should be recyclable and specific targets should be
set as to the proportion that should be recycled. The same approach should apply to
the recycling of glass, furniture, and waste electric and electrical equipment (WEEE).
R.33 In recognition that many of the improvements in waste management have come about
due to actions impacting on the supply chain, it is recommended that consideration
should be given to:
• compulsory EMS for members of particular trade associations;
• compulsory EMS for certain types of companies, including operators of relatively
large office facilities;
• development of a waste management charter which all organisations (above a
certain size) in London should be encouraged or required to adhere to;
• restricting the use of disposable containers for serving food and drink within all
London eat-in establishments, and where they are used, for the containers to be
highly recoverable;
• lobby for imposing a significant fee for the use of plastic bags provided by London
businesses, or prohibiting the use of non-recyclable plastic bags;
• introducing measures to promote the development and use of highly biodegradable
plastic bags in London; and
• to promote the recycling of all plastic bags in London.
R.34 It is recommended that research is carried out into the composition of waste in London
that is currently described as ‘general’ with the main focus being given to the following
industries since they produce the highest tonnages of waste in this category: food, drink
and tobacco; publishing, printing and recording; transport, storage, communications;
miscellaneous. Where relevant, consideration should be given to carrying out this
research in conjunction with trade associations with the aim of increasing the
participation of their members.
R.35 In developing the Wider Waste Strategy, it is recommended that the GLA liaises with the
National Health Service (NHS) to consider the implications of the soon to be published
NHS Waste Management Strategy. It is also recommended that the NHS should be
asked to provide data on the composition of its wastes and what disposal routes are
employed.
R.36 It is recommended that consideration should be given to adopting a strategic approach
to waste management across all London NHS Trusts in order to make more efficient use
of resources, and that the GLA should discuss the potential for such an approach with
NHS Estates.
R.37 It is recommended that the NHS should be encouraged to make it a requirement that all
new buildings and refurbishment projects should incorporate innovative waste transport
mechanisms such as vacuum powered chutes to minimise space requirements, and allow
segregation at source. These should include sufficient capacity for additional
segregation in the future, and ensure that clinical, non-clinical wastes, and special
wastes are handled in such a way as to prevent any risk of cross contamination.
132

R.38 It is recommended that consideration should be given in London to the way in which
data on commercial and industrial waste arisings and the wastes handled – by customer
type, customer size, and waste composition, could be obtained on a regular basis.
R.39 It is recommended that consideration should be given to what extent the use of LPG
and battery operated vehicles by waste collection authorities would be beneficial, and
how such a change could be implemented.
R.40 It is recommended that consideration should be given as to whether certain types of
service provision by waste collection authorities are more advantageous than others,
and, if so, how can additional support or information be given to such authorities in this
regard.
R.41 It is recommended that the GLA in conjunction with all London Boroughs should lobby
Government to enable sufficient commercial waste facilities to be provided to handle
London’s wider wastes (for example by adopting a similar approach to that of
Copenhagen where the municipality has responsibility for the management of all
commercial waste, including C&D waste, and sets criteria for the transport and
treatment of each waste type; only those facilities and operations that meet the criteria
can enter into a contract with the authorities to become designated waste management
facilities and operators).
R.42 In order to facilitate the provision of waste management facilities to serve London’s
needs, it is recommended that suitable sites for a full range of facilities (ie. not just
strategic facilities) are identified in Waste Local Plans in the light of consultation with
the Regional Technical Advisory Board (RTAB).
R.43 It is recommended an assessment is made of whether the use of environmental
management systems (EMS) and quality management systems (QMS) by local
authorities is likely to bring benefits with regard to sustainable waste management and,
if so, to consider whether the provision of additional support to the authorities would be
useful in this regard.
Recommendations: Construction and Demolition Wastes
R.44 It is recommended that the GLA make it clear that the arisings of ‘hard’ and excavated’
construction and demolition wastes in London may be considerably different to the
figure of 6.05 million tonnes that is often quoted from the Symonds’ surveys of 2001
and 2002 and subsequently used as the basis for further analysis. Such analyses should
recognise that the Symonds’ survey data should be used as a range (3.70-8.40 million
tonnes), with the associated confidence level, and acknowledge the potential for
significant uncertainty in the modelling results. An appropriate contingency should be
included within any strategy measures based on the data modelling to allow for a
significantly greater, or indeed lesser, quantity.
R.45 It should be made clear that ‘soft’ C&D wastes (eg. timber, plastics, metals, packaging,
plaster) are excluded from the Symonds’ survey data estimates, and future planning /
modelling should take steps to (a) allow for this in any future waste modelling analyses,
e.g. to inform the development of the London Plan, and (b) obtain data on the size and
composition of this waste stream.
R.46 It is recommended that the lack of reliable composition data is particularly taken into
account in light of the level of uncertainty of the Symonds survey data estimates for
London. Consideration should be given to commissioning a detailed survey of
construction and demolition wastes in London that would include (a) the separate
133

measurement of wastes from construction and demolition activities, and (b) detailed
compositional analysis of different types of construction project of relevance to London.
R.47 It is recommended that Government should be lobbied to impose financial instruments
and/or support other measures, such as demonstration projects and dissemination of
best practice, to promote the treatment and reuse – rather than disposal – of
contaminated soils from demolition and construction sites.
R.48 It is recommended that consideration should be given to the opportunities that exist to
improve the gathering of C&D waste management data, including cooperation with
trade associations and discussions with the Environment Agency with regard to
incorporation into licensing requirements.
R.49 It is recommended that the promotion of waste exchanges for C&D waste should not be
a priority in London at this point in time.
R.50 It is recommended that consideration should be given to how to adopt, or influence
Government to adopt, including those measures that have been effective in achieving
high recycling rates of C&D waste in other European Member States, such as:
• Banning or partial banning landfill of C&D waste.
• Requiring separation and re-use/recycling of C&D waste.
• Encouraging the use of the Sustainable Construction Code of Practice, and the
Demolition Protocol.
• Working with the C&D industry and trade associations to establish targets, and
methods to encourage separation, re-use and recycling.
• Enabling waste planning authorities to require developers to provide a demolition
plan with an associated C&D waste management plan before they are given
permission to demolish a building or structure, and to attach conditions to planning
permissions/building permits to stimulate the use of secondary materials.
Recommendations: Hazardous Wastes
R.51 It is recommended that caution should be exercised in relation to the number of
hazardous wastes landfill sites that it is anticipated will become available in the near
future; rather the situation should be monitored during the next few months since the
actual number of permitted hazardous waste sites may vary significantly from that
predicted.
R.52 It is recommended that in response to the prohibition of co-disposal of hazardous and
non-hazardous waste urgent consideration is given to the opportunities for on-site
treatment of contaminated soils, and the way in which the resultant increased costs of
brownfield site development may affect other policy objectives (eg. housing provision,
as well as short to medium term commercial development).
R.53 In the light of the anticipated significant increase in hazardous waste arisings under the
new Hazardous Waste Regulations, it is recommended that a separate investigation is
carried out into the likely quantity and type of these ‘new’ hazardous wastes to inform
the development of a strategy to improve the degree of London’s self-sufficiency in
managing such wastes.
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R.54 It is strongly recommended that in developing future policy for waste management in
London, the time required to plan, authorise and construct new facilities in providing
hazardous waste treatment facilities should be taken note of.
R.55 It is recommended that urgent consideration should be given to measures to address
this situation in the short to medium term. Such measures may include:
• An awareness raising campaign for London’s hazardous waste producers, particularly
focused on SMEs (refer also to recommendations on C&I wastes).
• Supporting contaminated land treatment technologies focusing on assessing and
promoting those most appropriate to London. This may include information
dissemination, showcasing technologies, assessment of technology used overseas,
assessment of the technical requirements for London, set-up of one or more major
interim treatment sites within easy reach of London (such as on former landfill
sites), and consideration of ways to support development that incorporates on-site
treatment methods.
• Supporting interim storage solutions for easily handled low volume, packaged
hazardous wastes.
R.56 Due to the short timescale until transposition of the Hazardous Waste Regulations, it is
recommended that developing a strategy for the treatment of London’s hazardous
wastes should be accorded a very high priority.
R.57 As part of London’s drive towards self-sufficiency in waste management, it is
recommended that ways to encourage the development of a hazardous waste
processing industry should be explored, particularly for the ‘new’ hazardous wastes that
will result from the implementation of the hazardous waste regulations in mid-2005. It is
recommended that a strategy is developed to mimimise and prevent illegal waste
management activities in London resulting from the advent of the new Hazardous Waste
Regulations.
R.58 It is recommended that steps are taken to better inform all waste producers - including
the large community of SME’s in London - about their statutory responsibilities with
respect to ‘controlled waste’ in general, and ‘hazardous waste’ in particular.
R.59 It is recommended that a strategy is developed to manage contaminated soil from
construction and demolition works in London, as a matter of urgency.
135

Future Actions
Table 7.1: Summary of Future Actions, Priorities, Timeframes and Parties
Recommendations / Future Actions Priority/
Timeframes 1
Theme 1: Data Improvement
1 Develop a data improvement programme for C&I wastes in
London. This should build on the national C&I waste
survey data but provide more compositional detail about
those sectors where least information is available. The
programme should include targeted surveys of commercial
wastes that are currently described as ‘general’ and on
industrial wastes to provide more information about the
breakdown and quantities. Due consideration should be
made as to how waste management companies could
provide data on commercial and industrial wastes handled
by customer type, customer size and composition.
NB this links with Actions 5-8 in the Mayor’s Municipal
Waste Strategy – relating to waste data reporting .
2 Carry out a survey of C&D wastes in London to provide
more robust data than is currently available from the
national C&D survey. The survey should include all C&D
waste materials (including soft C&D wastes) and provide
more information about the composition of the separate
construction and demolition waste streams.
3 Monitor the number of consented hazardous waste landfill
sites that become available for use – in July 2004.
NB this links with Action 82 in the Mayor’s Municipal
Waste Strategy – relating to planning the waste
infrastructure in London.
4 Carry out an investigation into the additional types and
quantities of hazardous wastes that will be generated as a
result of the implementation of the new hazardous waste
regulations – expected in July 2005. Use this information
(with the output from action 5) in the development of a
strategy to make London more self sufficient in hazardous
waste processing.
5 Approach the Environment Agency for access to their inhouse
database which provides information about the
onsite processing of hazardous wastes in London. Use
this information (with the output from action 4) in the
development of a strategy to make London more selfsufficient
in hazardous waste processing.
6 Consideration should be given to the future opportunities
that exist to improve the gathering of C&I and C&D waste
136
Responsible
Organisations
Key GLA, EA, LDA
Key GLA, ICE, BRE
Key EA,GLA
Short GLA, Hazardous
Waste Forum,
EA
Short GLA, EA
Medium GLA, EA, Trade
Associations

data, including discussions with Trade Associations and
the Environment Agency with regard to incorporating into
licensing requirements.
Theme 2: Lobbying of Government (policy, guidance or legislation changes)
1 A number of Development Planning issues should be
considered:
• Competition with housing for waterside
development
• Identification of land for waste management
• Inclusion of Demolition Protocol in planning
guidance / UDPs
• Consideration of transportation by rail or water
NB this links with Actions 82 & 83 in the Mayor’s
Municipal Waste Strategy – relating to Planning for Waste
Infrastructure.
2 Provide support to Transport for London in lobbying
government to support the use of the river and canal
network in London for waste transportation.
NB this links with Actions 87 and 88 in the Mayor’s
Municipal Waste Strategy – relating to the encouragement
of sustainable waste transportation in London (including
rail and water).
3 Provide support to British Waterways in their efforts to
lobby Government to amend the regulations relating to
Freight Facility Grants with respect to water and rail
transportation.
4 Lobby Government to ensure the continued operation of
the Envirowise programme for businesses and for its
expansion to cover all commercial businesses and provide
more detailed advice on waste management practice,
particularly for SMEs.
5 Lobby Government, the Environment Agency and other
relevant organisations with a view to improving access to
clear and consistent advice on good practice in waste
management, through the development of a single portal
for waste management guidance information (possibly as
part of the development of a single portal for wider
environmental, health and safety guidance).
6 The Government should be lobbied in order to address the
provision of commercial waste management facilities in
London.
137
Associations
Key GLA, ALG, LWA
Key Transport for
London, GLA,
EA
Short GLA, British
Waterways
Short GLA, Envirowise
Medium GLA,
Environment
Council
Medium GLA,EA

Theme 3: Support for Existing Initiatives (including Mayor’s Municipal Strategy)
1 Provide support for the WRAP programme to ensure that
start–up assistance and funding is available for SME
recycling and processing businesses in London.
2 Provide support to London’s local authorities to advise
SMEs about sources of assistance on waste-related
matters (as many SME’s seek assistance from local
authorities in the first instance).
3 Liaise with the National Health Service (NHS) to consider
the implications of the NHS Waste Management Strategy,
which is due for publication soon. Consideration should
be given to adopting a strategic approach across all
London NHS Trusts and to require the specific
consideration of waste management issues in all NHS
Estates new build and refurbishment works.
NB this links with Action 67 in the Mayor’s Municipal
Waste Strategy – relating to best practice in the collection
of clinical wastes.
4 Provide assistance and advice to Envirowise to ensure that
data on the companies in London approaching Envirowise
and the nature of their enquiries is compiled on a
systematic basis.
5 Provide support for the Mayor’s Green Procurement Code
and seek to extend the use of this by encouraging large
waste producers to enter into long term recycling
contracts using this code.
NB this links with Action 80 in the Mayor’s Municipal
Waste Strategy – relating to the promotion of the Mayor’s
Green Procurement Code.
6 Encouragement should be given to harmonise business
waste management activities and for future funding
support to be directed to this end. Discussions should be
held with relevant trade associations to see to what extent
company members can be encouraged to adopt
sustainable waste management practices.
NB this links with Action 81 in the Mayor’s Municipal
Waste Strategy – relating to the promotion of Business
Efficiency.
7 The increased use of Environmental Management Systems
(EMS) should be encouraged amongst London’s business
community, including SMEs in both the commercial and
industrial sectors. An assessment of whether the use of
EMS and QMS in local authorities is likely to bring
measurable benefits. Collaboration with the LDA should
138
Short GLA, WRAP,
London ReMade
Short GLA, ALG
Short GLA, NHS
Medium GLA, Envirowise,
ALG
Medium GLA, LDA,
London ReMaDe
Medium GLA, LDA
Medium GLA, LDA,
Envirowise,
IEMA

continue. Consultations should be carried out with
Envirowise and the Institute of Environmental
Management and Assessment (IEMA) to determine the
level of support that they are able to provide.
NB this links with Action 81 in the Mayor’s Municipal
Waste Strategy – relating to the promotion of Business
Efficiency.
8 The increased use of Environmental Reporting should be
encouraged amongst London’s major businesses and
guidance and best practice references produced, including
the key performance indicators that companies should
report on. The use of a centralised database on the social
and environmental performance of companies will greatly
supplement this process.
Theme 4: Raising Producer Awareness (including SME’s)
1 Research should be carried out into the effectiveness of
possible incentives to improve the environmental
performance of SMEs, rather than costs alone.
2 A reduction in the use of glass, paper, cardboard and
plastics should be promoted in the commercial sector,
incorporating recycled materials in product procurement.
A similar approach should be adopted for furniture and
electrical and electronic equipment.
NB this links with Action 69 in the Mayor’s Municipal
Waste Strategy – relating to education and promotion
Theme 5: New Initiatives
1 Develop and implement a programme to tackle any
possible increase in illegal waste management activities
that may occur from July 2004, after the ending of codisposal
of non-hazardous and hazardous wastes. This is
likely to include:
• Publicity campaign (with a particular focus on
SMEs).
• Increased surveillance (e.g. environmental
wardens, CCTV).
• Increased penalties for offenders.
2 Develop and implement a programme of actions as a
matter of urgency to mitigate the effects on London’s
brownfield site development programme, resulting from
the imminent lack of hazardous waste landfills in London.
This should include:
• Establishment of one or more treatment sites
139
Medium GLA, LDA,
Envirowise,
IEMA
Medium GLA, Envirowise,
NetRegs
Medium GLA, London
ReMade
Key GLA, ALG, EA
Key GLA, ICE, BRE

for contaminated soils within London.
• Consideration of the time delay associated with
the on-site treatment of contaminated soils
and the increased costs of brownfield site
development.
• Promotion of contaminated land treatment
technologies.
• Information dissemination to developers and
contractors.
3 Develop and implement a programme to assist SMEs with
the management of their hazardous waste. This should
include:
• An awareness raising campaign about
hazardous waste.
• Provision of interim storage solutions for easily
handled low volume packaged hazardous
wastes.
4 Develop and implement a strategy to encourage the
development of a hazardous waste processing industry in
London, especially in light of the likely lag time associated
with the planning process and public attitudes of NIMBY.
This should build on London’s existing industry and take
account of the likely type and quantity of new hazardous
wastes under the new definition (from July 2005).
NB this links with Action 82 in the Mayor’s Municipal
Waste Strategy – relating to planning the waste
infrastructure in London.
5 Liaise with WRAP, the LDA and London ReMaDe to review
the prioritisation accorded by these organisations to
particular waste streams for recycling and reprocessing.
Use the results of this as input into the Wider Waste
Strategy and consider setting education and recycling
targets for each as part of the Strategy.
NB this links with Action 76 in the Mayor’s Municipal
Waste Strategy – relating to developing markets for
recyclable materials.
6 Consider how to influence Government to adopt, those
measure that have been effective in achieving high
recycling rates of C&D wastes in other European Member
States, such as:
• banning / partial banning of landfill of C&D
wastes.
• requiring separation and re-use/ recycling of
140
Key GLA, Haz Waste
Forum, Trade
Associations
Short GLA, Hazardous
Waste Forum,
EA
Short GLA, WRAP,
LDA, London
ReMaDe
Medium GLA, ICE, BRE

C&D waste.
• requiring the use of the London Sustainable
Construction Code and Demolition Protocol
prior to giving developers permission to
proceed with a demolition and construction
project.
7 Develop and publish a best practice guide for the
management of waste resulting from large-scale public
events.
8 Subject to the views of NetRegs, carry out a more detailed
survey of waste management practice of commercial SMEs
in London (to augment the results of the SME-nvironment
survey 2003)
9 The feasibility of establishing medium/large scale biogas
facilities for the processing of London’s organic waste
should be investigated, including the feasibility of using
the biogas and heat from such facilities in co-located
industrial sites.
Medium GLA, ALG
Medium GLA, Envirowise,
EA
Medium GLA, London
ReMade, EA,
DEFRA
1 Key to priorities (used in conjunction with the Mayor’s Municipal Waste Strategy):
Key – requires immediate attention
Short – requires attention in the short term (6 to 12 months)
Medium – requires attention in the medium term (12 to 24 months)
141

Appendix A: Waste policy and legislation
European Policy
In 1987 the Single European Act amended the Treaty of Rome (the legislation that established
the European Commission (EC)) to include a strategic environmental protection aim. Article
130R of the Act set out the basic principles of EU environmental policy, as follows:
• Preventative action is preferred to remedial measures;
• Environmental damage should be reflected at source;
• The polluter should pay for the costs of any measures to protect the environment
(polluter pays principle);
• Environmental policies should form a component of the other policies.
The European Commission’s 1989 Waste Management Strategy built on these overarching
environmental principles and formed the basis of the European Union’s waste management
policy.
Waste hierarchy
The cornerstone of European waste policy is the ‘waste hierarchy’, which supports the
objectives of environmental protection and sustainability. The hierarchy identifies that the
most effective environmental solution is to reduce the generation of waste (i.e. reduction).
Where further reduction is not practicable, products can sometimes be used again (re-use).
Failing that, value should be recovered from the waste through recycling, composting or energy
recovery. Only if none of the above offers an appropriate solution should waste disposal be
considered as an option.
Proximity Principle
The proximity principle requires that waste should generally be managed as near as possible to
its place of production, mainly because transporting waste has a significant environmental
impact. The proximity principle places a responsibility on the producers of waste to be
responsible for the waste produced. This is because waste should as far as possible be dealt
with ‘on the doorstep’ as opposed to exporting the problem somewhere else.
Self-sufficiency
The principle of self-sufficiency requires that most waste should be treated or disposed of
within the area in which it is produced. Each region, or sub-regions in some cases, should
provide for facilities with sufficient capacity to manage the anticipated quantity of waste
needing to be dealt with within that area for at least 10 years.
Subsequent strategies have reaffirmed and built upon these principles which are being
established though legislation.
Sixth Environmental Action Programme
The EC has recently launched ‘The Sixth Environment Action Programme (EAP)’ which forms
the environmental element of the EU’s Sustainable Development Strategy. It identifies four
environmental areas to be tackled, one of which is entitled ‘Natural Resources and Waste’. This
places emphasis on the need for a series of cross-cutting inter-related measures to reduce the
environmental impact of resource use. One component of the 6 th EAP is to develop seven
‘Thematic Studies’ for environmental issues that require a more holistic approach, one of which
will be specifically on the prevention and recycling of waste.
143

European Legislation
The EU’s waste policy is delivered though a series of Directives which fall broadly into three
categories:
• horizontal legislation – establishing the overarching framework for waste
management;
• treatment specific legislation – relating to a particular method of waste
management;
• stream specific legislation – relating to a particular type of waste, or waste stream.
Not all the Directives relate directly to non-municipal controlled waste streams, although most
will have an impact. There are also a number of Directives that will indirectly have an influence
on waste management, such as the Habitats Directive (these are not covered here).
Horizontal Legislation
Waste Framework Directive (75/442/EEC as amended)
This Directive establishes the overarching framework for the management of waste across the
EU, setting out in law the policy principles of the waste hierarchy (prioritising waste prevention,
reuse and recovery), the polluter pays principle (ensuring the waste producer bears the cost of
treatment/disposal), and the need to dispose of waste without harming human health or the
environment.
The Directive is also influential because it establishes the need for Member States to prepare
Waste Management Plans, and prohibits the uncontrolled disposal of waste.
Hazardous Waste Directive (91/689/EEC, as amended)
Waste that is potentially hazardous to human health or the environment is covered by
additional legislation. The Hazardous Waste Directive sets out a common definition of
‘hazardous waste’ and details what can be included as hazardous and its properties. There is
also greater control on the movement of hazardous waste with Member States having to draw
up Hazardous Waste Plans and enforce stricter controls over waste management operations
handling hazardous waste, including record keeping, the mixing of waste streams, and the
shipment of waste.
Treatment Specific Legislation
Landfill Directive (99/31/EC)
The Landfill Directive requires Member States to secure a progressive reduction in the amount
of biodegradable waste going to landfill. Specifically, the targets to be achieved are to reduce
the volume of biodegradable municipal waste going to landfill:
• to 75% of the 1995 weight by 2010;
• to 50% of the 1995 weight by 2013;
• to 35% of the 1995 weight by 2020.
The Landfill Directive also requires the banning from landfill of:
• waste which is corrosive, oxidising, highly flammable, flammable or explosive;
• liquid hazardous waste, infectious hospital or other clinical waste;
144

• whole used tyres (from 2003);
• shredded tyres (from 2006).
The Directive requires classification of landfills as suitable for hazardous, non-hazardous or inert
waste and prohibits co-disposal after July 2004. It requires that waste must be pre-treated
before being landfilled and that landfill gas must be collected, treated and used to produce
energy or flared off.
Directive on Waste Incineration (2000/76/EC)
The Waste Incineration Directive (2000/76/EC) aims to prevent, or, where not practicable, to
reduce as far as possible, negative effects on the environment caused by the incineration and
co-incineration of waste. In particular, it aims to reduce pollution caused by emissions to the
air, soil, surface water and groundwater, potentially posing a risk to human health. Stringent
operational conditions and technical requirements are being implemented, introducing far
stricter provisions than those defined in the existing Municipal Waste Incineration Directives
(89/369/EEC and 89/429/EEC) and Hazardous Waste Incineration Directive (94/67/EC).
The deadline for conversion of existing plants will be 28 December 2005, when the 1989 and
1994 Directives will be repealed.
Integrated Pollution Prevention and Control Directive (96/61/EC)
The Integrated Pollution Prevention and Control (IPPC) Directive (96/61/EC), established in
August 2000, requires a range of prescribed processes (including many waste management
processes) to obtain an authorisation (permit) from the licensing authorities within the Member
States for major industrial and waste sites covering air, water and land pollution. Without the
permit, they are not allowed to operate. These permits are based on the concept of Best
Available Techniques (BAT – as defined by the Directive) for the prevention or, where not
possible, reduction of pollution.
The permits must consider the environmental performance of the installation, assessing
emissions to air, water and land, generation of waste, use of raw materials, energy efficiency,
noise, prevention of accidents, risk management etc.
As from October 1999, the Directive applied to all new installations, as well as existing
installations that intend to carry out changes which may have a significant effect on human
health or the environment. Other installations have been granted a further 8 year period of
grace.
Waste management processes will also need to satisfy the principles of ‘Best Practicable
Environmental Option’ (BPEO) which, in addition to controlling emissions, specifically requires
cross-media pollution considerations (for example, ensuring process residues, when finally
discharged, do not result in the transfer of harmful pollutants).
Stream Specific Legislation
Waste Electrical and Electronic Equipment Directive (2002/96/EC)
The Waste Electrical and Electronic Equipment (WEEE) Directive applies to ‘equipment which is
dependent on electrical currents or electro-magnetic fields in order to work properly’. The
responsibility for meeting the requirements of the WEEE Directive falls directly on the producer.
Specific initiatives include:
• prevention of waste, through minimizing the use of dangerous substances, improved
design, manufacture and coding;
145

• collection and treatment by establishing collection systems, including free take back
systems, and selective treatment of equipment;
• recovery and re-use systems to be established, including specific targets for
different categories of WEEE, ranging from 70-80%;
• strengthening of producer responsibility requirements.
Packaging and Packaging Waste Directive (94/62/EC)
The Directive on Packaging and Packaging Waste (94/62/EC) established targets for the
recovery and recycling of packaging waste.
The Directive is implemented in the UK by the Producer Responsibility (Packaging Waste)
Regulations 1997.
Batteries and Accumulators Directive (91/157/EC)
Key Features
• Prohibits placing on the market manganese alkaline batteries designed from
prolonged use in extreme conditions and containing more than 0.05% by weight of
mercury, and any other battery with a mercury content of more than 0.025% by
weight.
• Requires every effort towards the collection of used batteries and accumulators with
the view to their recovery or disposal.
• Requires batteries to be marked to indicate separate collection, recycling and heavy
metal content.
• Requires Member States to draw up programmes to reduce the heavy metal content
of batteries and accumulators.
• Collection targets of 75% and recycling targets of 55% are currently proposes for
portable batteries in general.
Waste Streams addressed:
Batteries (except those composed of elements of the button type) and accumulators
End of Life Vehicles Directive (2000/53/EC)
Key Features:
• Aims to prevent waste from end of life vehicles and promote the collection, reuse
and recycling (waste hierarchy) of their components.
• Requires producers, dismantlers and shredders to establish collections systems for
end of life vehicles.
• Sets recycling targets for economic operators – by the 1 st January 2006, reuse and
recovery is to increase to a minimum of 85% and re-use and recycling to 80%, and
by the 1 st January 2015 reuse and recovery to 95% and reuse and recycling to 85%.
Waste Streams addressed:
End of Life Vehicles
146

UK Policy
The majority of UK waste management policy is drawn directly from European policy, and
legislation transposed into UK statute.
Waste Strategy 2000
Key Features
• Waste Strategy 2000 is the principal document setting out overall strategy of
challenges, targets and mechanisms for change.
• The Strategy sets the target of reducing industrial & commercial waste landfilled to
85% of 1998 levels by 2005.
• Emphasises the use of the Landfill Tax escalator as the key tool to reducing landfill.
• Sets statutory performance standards for local authority recycling in England.
• Promotes research into the development of markets for recyclate through the
establishment of the Waste and Resource Action Programme (WRAP).
• Indicates intent to strength and widen the role of producer responsibility initiatives,
the reduction and re-use of packaging and the recycling and recovery of packaging
waste.
• Recognises the need for authorities to use energy recovery facilities, although
emphasises that they should be ‘appropriately sized to avoid competition with
recycling’, and the ‘opportunities for incorporating Combined Heat and Power
technology should always be considered’.
• Reinforces the need to act upon and meet the targets set out in European
legislation.
• Affirms the use of Best Practicable Environmental Option (BPEO), the proximity
principle, and the waste hierarchy.
Waste streams addressed:
Has an impact on the management of waste through categories of source (municipal, C&I, C&D
etc.), categories of nature (inert, hazardous etc.), and categories of type (plastic, tyres,
batteries etc).
Waste Not, Want Not – A review of Waste Strategy 2000 by the Prime Minister’s
Strategy Unit (2002)
Key Features
• Not Government policy but a series of recommendations on the ‘economic and
regulatory framework’, ‘strategic investment measures’, and ‘funding and delivery’.
• Suggests increasing the landfill tax by £3 per tonne in 2005/06 and by at least £3
per tonne each year thereafter to a medium to long-term rate of £35 per tonne.
• Increase the Government’s green procurement.
• Led to the formation of DEFRA Waste Implementation Programme (WIP).
• Government responded in 2003 with the Government Response to Strategy
Unit Report ‘Waste Not, Want Not’ (DEFRA, 2003), generally endorsing the
recommendations and proposing actions to take them forward.
147

Waste streams addressed:
Applies to all
Planning Policy Guidance Note 10 - Planning and Waste Management (1997)
Key Features
• Sets out guidance, material to planning applications, how the land-use planning
system should contribute to sustainable waste management, and criteria for siting
facilities.
• Primarily concerned with controlled waste and does not favour particular waste
management solutions.
• London boroughs remain the unitary development planning authority.
Waste streams addressed:
Applies to all.
Proposed changes:
PPG 10 is currently being reviewed in line with the reforms to the planning system.
UK Legislation
Environmental Protection Act 1990
Key Features
• Sets out the requirements for Waste Management Licensing and prohibits the
unauthorised or harmful depositing, treatment or disposal of waste.
• Introduces ‘Duty of Care’ (amended February 2003).
• Sets out the terms for the collection, disposal or treatment by the appropriate
authority for controlled waste and making special provision for ‘special waste’.
Waste streams addressed:
Applies to all.
Environment Act 1995
Key Features
• Requires the production of a National Waste Strategy.
• Establishment of the Environment Agency as the Competent Authority on waste.
• Introduces the principle of BPEO for each waste stream.
• Introduces Producer Responsibility Obligations
Waste streams addressed:
Applies to all.
Control of Pollution Act 1974 (Part 11) - Scotland
Key Features
148

• Requires consents to discharge trade effluent to sewer, which specify the nature and rate of
discharge.
• Conditions are set for consents which are not to be breached.
• Consents are issued by sewage undertakers in England, Scotland and Wales, and by the
Water Service in Northern Ireland.
Waste streams addressed:
Applies to all.
Pollution Prevention and Control Act 1999 and Pollution Prevention and Control
(England and Wales) Regulations 2000 as amended
Key features
• To gain a permit, operators will have to show that they have systematically developed plans
to apply the “Best Available Techniques” (BAT) and meet certain oterh requirements, taking
account of relevant local factors. For example, there is specific guidance on BAT for waste
minimisation which includes:
o Analysing the use of raw materials and assessing the opportunities for reduction
o Assessing opportunities for improved process efficiency and waste reduction
• All IPPC installations are required to apply for a permit to operate and there is a phased
timetable, beginning in 2001 and ending in 2007, depending on the industry sector.
Waste streams addressed:
Applies to all
Controlled Waste Regulations 1992
Key Features
• Provides the legal definitions of controlled waste , indicating what should and
should not be considered as household, commercial or industrial (including
construction and demolition) waste.
• Describes which types of litter are included as controlled waste.
Waste streams addressed:
All controlled waste.
Waste Management Licensing Regulations 1994
Key Features
• Transposes the EU Waste Framework Directive into UK statute, requiring the
Directive to be taken into account when drawing up Waste Management Plans.
• Enhances the licensing and monitoring of waste management set out in the
Environmental Protection Act.
Waste streams addressed:
Applies to all.
149

Special Waste Regulations 1996
Key Features
• Implements the EU Hazardous Waste Directive in the UK.
• Defines special waste (hazardous waste)
• Sets out the requirements and procedures for carrying and disposing of hazardous
waste, including tracking waste movements.
Waste streams addressed:
Hazardous waste.
Proposed Changes:
• The Landfill Regulations 2002 introduced the term ‘hazardous waste’ to replace the
‘special waste’.
• Amendments are due to be made to take into consideration recent changes to the
European Waste Catalogue, including the requirement to separate special waste,
where it is mixed with other waste, if it is economically and technically possible.
Hazardous Waste Regulations
Due to replace the Special Waste Regulations in 2004.
Waste and Emissions Trading Act 2003
Key Features
• Tool to meet the targets set by the Landfill Directive for diverting biodegradable
municipal waste (BMW) from landfill.
• Provides for the allocation of allowances, which may be tradable, to waste disposal
authorities.
Waste streams addressed:
Principally Biodegradable Municipal Waste.
Waste Minimisation Act 1998
Key Features
• Enables waste collection authorities or waste disposal authorities to make
arrangements to minimise the generation of controlled waste in their area.
Waste streams addressed:
All controlled waste.
Landfill (England and Wales) Regulations 2002
Key Features
• Implements the EU Landfill Directive (apart from the diversion of BMW from landfill
targets) and the European Waste Catalogue into UK legislation.
• Requires landfills to be classified as hazardous, non-hazardous, or inert, and
prevents the co-disposal of hazardous and non-hazardous waste after July 2004.
150

• Prohibits certain types of waste being disposed of in landfill including:
• any waste in liquid form;
• waste which, in the conditions of landfill, is explosive, corrosive, oxidising,
flammable or highly flammable;.
• hospital and other clinical wastes;.
• chemical substances arising from research and development or teaching
activities;.
• whole tyres (from 2003);.
• shredded tyres (from 2006);.
• Establishes a set of Waste Acceptance Criteria, and the general requirements for all
landfill sites.
Waste streams addressed:
Hazardous, non hazardous or inert waste.
Landfill Tax Regulations 1996
Key Features
• The Regulations set out the basis for the tax aimed at encouraging waste producers
to produce less waste and recover more value from their waste.
• Acts as a mechanism to off-set the cost of landfill to make alternatives more
competitive.
• At 1 April 2004 the Landfill Tax rate for active waste increased by £1 to £15 per
tonne. The rate for inactive waste remains at £2 per tonne. The Chancellor’s Pre-
Budget Report 2002 announced that the Landfill Tax for active waste would be
increasing by a minimum of £3 per tonne from 2005-06, until it reaches a rate of
£35 per tonne in the medium to long term.
• Through the Landfill Tax Credit Scheme, landfill site operators who make
contributions to bodies with objects concerned with the environment, enrolled
under the Landfill Tax Credit Scheme, may claim a credit against their annual landfill
tax liability. The maximum credit that they may claim currently is 6.5 per cent of
that liability.
Waste streams addressed:
All waste sent to landfill.
Proposed Changes:
Will be raised by at least £3 year on year to £35/tonne.
Aggregates Levy (under the Finance Act 2001)
Key Features
• The objective of the levy is to address the environmental costs associated with
quarrying operations and to reduce demand for aggregate and encourage the use of
alternative materials where possible.
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• The standard rate is currently set at £1.60 per tonne.
Waste streams addressed:
Potential to reduce dependency on the extraction of primary aggregate, creating demand for
secondary material.
Producer Responsibility Obligations (Packaging Waste) Regulations 1997
Key Features
• Places responsibility on business with an annual turnover greater that £2million and
handling more then 50 tonnes of packaging each year to recover specific tonnages
of packaging according to the activity they perform.
• They must also register with the Environment Agency or a compliance scheme,
demonstrate that their obligations have been met, and inform consumers as to how
they are increasing recycling and recovery.
Waste streams addressed:
Packaging waste.
Proposed Changes:
Targets will rise in response to current negotiations at the European level.
Packaging (Essential Requirements) Regulations 1998
Key Features
• The volume and weight of packaging must be minimised, consistent with the level
necessary for safety, hygiene and acceptance by the consumer.
• The design and use of packaging in a manner that permits its reuse and recovery.
• Limits the concentration of lead, cadmium, mercury and hexavalent chromium in
packaging.
Waste streams addressed:
Packaging waste.
End of Life Vehicles Regulations
Key Features
• Came into effect on the 3 rd November 2003
• Regulations to introduce the licensing of authorised End of Life Vehicle treatment
sites
• Outlines how authorised handlers should dismantle, recycle and dispose of vehicle
materials
• Proposes that producers should pay the costs of all end of life vehicles from 2007
Waste Streams addressed:
End of Life Vehicles
152

Green Paper on PVC
Key Features
• Presents and assesses various environmental issues that occur during the life cycle
of PVC (Poly vinyl chloride), which include human health aspects.
• Considers, in view of sustainable development, a number of options to reduce the
impacts that need to be addressed.
Waste streams addressed:
PVC
153

Appendix B: Consultees for Commercial and Industrial Waste
Waste Management Company/
Organisation
Response
Bywaters Unable to make contact with the
appropriate individual
Shanks East London Essentially only municipal in London
Biffa Waste Services Detailed response
Cory Environmental Detailed response
Cleanaway Detailed response
Grundons Detailed response
Onyx Detailed response
Waste Recycling Group (WRG) Detailed response
SITA Detailed response
MRS Environmental Services Essentially only municipal in London
Ahern Waste Management Services Unable to assist with the project
LondonWaste Ltd Provided some information
Viridor Do not collect in London
Thames Waste Management Detailed response
Kershire Plant Hire Ltd No response
A1 Waste Disposal Unable to assist with the project
City and Borough Waste Services No response
Carlton Doyle Waste Management Unable to make contact with the
appropriate individual
Allen Waste Management Unable to make contact.
Grosvenor Waste Management Detailed response
London Remade Detailed response
London Development Agency Detailed response
London Waste Action Detailed response
London First Detailed response
Waste and Resources Action Programme Detailed response
154

Chris Searles, Searles Associates Detailed response
Environmental Services Association Detailed response
Envirolink Detailed response
3Re Detailed response
Business Link for London Unable to make contact with the
appropriate individual
Day Aggregates Unable to make contact with the
appropriate individual
155

Appendix C: London’s Companies by Size and Sector (Data Based on
Small Business Service Website)
156

Table C1. Data by Number (from Small Business Service Website)
All Agriculture Mining etc Construction
Wholesale Transport Financial Services
Number 644865.00 2970.00 43030.00 89480.00 98190.00 44565.00 212570.00 154060.00
Micro (0-9) Employment 1057.73 4.90 78.01 114.20 229.66 60.94 350.97 219.05
Turnover 103587.50 187.86 7269.50 7625.73 37341.08 6777.56 32198.27 12187.49
Number 23960.00 60.00 2980.00 1365.00 6600.00 1210.00 7950.00 3795.00
Small (10-49) Employment 447.19 * 58.16 24.54 119.59 * 148.98 71.83
Turnover 80712.23 * 6633.61 3152.66 36842.45 * 23790.18 5185.92
Number 4115.00 5.00 585.00 160.00 990.00 295.00 1525.00 550.00
Medium (50-249) Employment 419.87 * 59.23 * 96.79 * 159.72 56.01
Turnover 79963.67 * 11516.84 * 29249.72 * 22250.81 5584.46
Number 615.00 0.00 85.00 25.00 135.00 50.00 245.00 75.00
Large (250-499) Employment 214.78 * 28.64 * 46.54 18.94 86.49 24.44
Turnover 44534.71 * 5895.90 * 23501.77 4475.14 7891.97 1240.19
Number 715.00 0.00 90.00 20.00 145.00 70.00 270.00 125.00
Very Large (500+) Employment 2336.70 * 165.42 * 644.19 522.63 667.64 294.09
Turnover 231823.40 * 41982.45 * 76800.53 56182.49 32740.76 18092.85
Total Number 674270.00 3035.00 46770.00 89685.00
106060.00 46190.00 222560.00 158605.00
Total Employment 4056.39 * 389.46 * 1136.77 * 1413.80 665.41
Total Turnover 540621.52 * 73298.30 * 203735.53 * 118871.99 42290.92
157

Table C2. Data by percentage ( from Small Business Service Website)
All Agriculture Mining etc Construction
Whosale Transport Financial Services
Number 95.64 97.70 92.00 98.26 92.59 96.48 95.51 97.13
Micro (0-9) Employment 23.63 68.36 20.03 55.42 20.20 9.27 24.82 32.92
Turnover 19.16 52.39 9.92 36.50 18.33 8.35 27.09 28.82
Number 3.55 1.97 6.37 1.50 6.22 2.62 3.57 2.39
Small (10-49) Employment 9.99 * 14.93 11.91 10.52 * 10.54 10.79
Turnover 14.93 * 9.05 15.09 18.08 * 20.01 12.26
Number 0.61 0.16 1.25 0.18 0.93 0.64 0.69 0.35
Medium (50-249) Employment 9.38 * 15.21 * 8.51 * 11.30 8.42
Turnover 14.79 * 15.71 * 14.36 * 18.72 13.20
Number 0.09 0.00 0.18 190.00 0.13 0.11 0.11 0.05
Large (250-499) Employment 4.80 * 7.35 * 4.09 2.88 6.12 3.67
Turnover 8.24 * 8.04 * 11.54 5.51 6.64 2.93
Number 0.11 0.00 0.19 0.02 0.14 0.15 0.12 0.08
Very Large (500+) Employment 52.20 * 42.47 * 56.67 79.48 47.22 44.20
Turnover 42.88 * 57.28 * 37.70 69.21 27.54 42.78
Total Number 100.00 99.84 100.00 289.96 100.01 100.00 100.00 100.00
Total Employment 100.00 * 100.00 100.00 * 100.00 100.00
Total Turnover 100.00 * 100.00 100.00 * 100.00 100.00
158

Appendix D: Results of Further Analysis of C&I Compositional Data
Commercial Wastes
As described in the C&I chapter, the SWMAL report estimates that 4.35 million tonnes of
London’s waste is of commercial origin. This comprises six sectors, i.e. wholesale, retail, hotels
and catering, finance, education, and other business and public administration. Across these six
sectors, a total of 81% (3.5 million tonnes) of the wastes are described as ‘general and
biodegradable’ which indicates that there is little data about their composition. Of the
remainder of the commercial waste streams, the SWMAL estimates that 10% (454,000 tonnes)
is paper and card, 2.6% (114,000 tonnes) is contaminated general, 2% (86,000 tonnes) is
metals and scrap equipment, 1.4% (61,000 tonnes) is food, another 1.4% is chemical and other
wastes, 1.1% is inert and construction and demolition wastes, and 0.09% (4,000 tonnes) are
mineral wastes and residues.
We have used the compositional data from the SWAP report (City of Westminster Waste
Analysis, SWAP, April 2001) (detailed in the C&I chapter) to try and reduce the uncertainties
caused by the large amount of waste described as general in the commercial waste stream in
the SWMAL. This was done by applying the percentage compositions from the SWAP report for
each of the three sectors surveyed (retail, hospitality and office) to the total tonnages for each
of the relevant sectors in the SWMAL. These are described sector by sector below.
The estimated composition of retail wastes for London based on the application of the SWAP
report is presented in Table D1 below. From this table it can be seen that over 600,000 tonnes
of the total waste stream of nearly one million tonnes are estimated to be paper and cardboard
wastes, of which over 530,000 tonnes are expected to be potentially recyclable. Of the other
major element of this waste stream, some 65,000 tonnes of the 120,000 tonnes of plastic are
potentially recyclable and 46,000 tonnes of the 83,000 tonnes of putrescible wastes are
likewise potentially recyclable (i.e. compostable).
Table D1: Estimated composition of retail wastes
Total Recyclable Non-Recyclable
% Tonnes % Tonnes % Tonnes
Paper 27 250.8 20.3 188.6 7.2 66.9
Cardboard 40 371.6 37 34.4 3.6 33.4
Glass 3 27.9 2.9 26.9 0.2 1.9
Plastic 24 120.8 7 65 5.9 54.8
Ferrous metals 2 9.3 0.3 2.8 0.3 2.8
Non-ferrous
metals
2 9.3 0.5 4.6 0.1 0.9
Putrescible 9 83.6 5 4.6 4.2 39
Textiles 2 18.6 0 0 2 18.6
Miscellaneous
combustible
2 18.6 0 0 2.1 19.5
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Miscellaneous
non-combustible
Particles passing
through a 20mm
sieve
1 9.3 0 0 0.4 3.7
1 9.3 0 0 1.4 13
Total 928.9 73 678.1 27.4 254.5
Notes: percentages are taken from the SWAP report. Figures are rounded up.
The estimated composition of hospitality wastes for London based on the application of the
SWAP report is presented in Table D2 below. From this table it can be seen that over 245,000
tonnes of the total waste stream of over half a million tonnes are estimated to be glass, of
which all but a tiny fraction are expected to be potentially recyclable. Putrescible wastes are
estimated to be approximately 120,000 tonnes in total, of which just over half (i.e. 72,000
tonnes) are potentially recyclable (i.e. compostable). Cardboard is a significant waste stream,
with an estimated 22,000 tonnes of the 66,000 tonnes expected to be recyclable. Paper is also
important, although a greater amount (46,000 tonnes) is expected to be non-recyclable than
recyclable (22,000 tonnes). Similarly, more plastics (34,000 tonnes) are estimated to be nonrecyclable
than recyclable (8,000 tonnes).
Table D2: Estimated composition of hospitality wastes
Total Recyclable Non-Recyclable
% Tonnes % Tonnes % Tonnes
Paper 11 65.9 3.7 22.2 7.7 46.1
Cardboard 12 71.9 9.4 56.3 2.1 12.6
Glass 41 245.5 42.4 252.7 0.1 .6
Plastic 7 41.9 1.3 7.8 5.7 34.1
Ferrous metals 2 12 1.5 9 0.6 3.6
Non-ferrous
metals
1 6 0.5 3 0 0
Putrescible 20 12 12.1 72.3 8.1 48.5
Textiles 1 6 0 0 0.6 3.6
Miscellaneous
combustible
Miscellaneous
noncombustible
Particles passing
through a 20mm
sieve
1 6 0 0 0.8 4.8
0 0 0 0 0.3 1.8
4 24 0 0 3.8 22.8
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Total 100 598.8 70.7 423.4 29.8 178.4
Notes: percentages are taken from the WASP report. Figures are rounded up.
The estimated composition of office wastes for London based on the application of the SWAP
report is presented in Table D3 below. The SICC sectors of finance and other business and
public administration used in the SWMAL have been combined to provide a total estimated
waste stream for office wastes. It is acknowledged that this may cause some inaccuracies for
estimating office wastes. From this table it can be seen that the overwhelming amount of the
total wastes (1.3 million tonnes) are estimated to be paper wastes. Of this, the majority (1.1
million tonnes) are estimated to be potentially recyclable. Putrescible wastes are estimated to
be just under 200,000 tonnes in total, of which the majority (i.e. approximately 165,000
tonnes) are potentially recyclable (i.e. compostable). The vast majority of the estimated
149,000 tonnes of cardboard is also expected to be recyclable. Likewise, the majority of the
99,000 tonnes of glass is also potentially recyclable. Conversely, the majority (133,000 tonnes)
of the plastic wastes is non-recyclable rather than recyclable (20,000 tonnes).
Table D3: Estimated composition of office wastes
Total Recyclable Non-Recyclable
% Tonnes % Tonnes % Tonnes
Paper 65 129 53.6 1,065.7 12.3 244.6
Cardboard 7 139 6.5 129.2 0.6 12
Glass 5 99 4.5 89.5 0 0
Plastic 8 159 1 19.9 6.7 133.2
Ferrous metals 1 20 0.3 6 0.5 9.9
Non-ferrous
metals
1 0 0.7 14 0 0
Putrescible 10 199 8.3 165 1.4 27.8
Textiles 1 20 0 0 0.6 11.9
Miscellaneous
combustible
Miscellaneous
non-combustible
Particles passing
through a 20mm
sieve
0 0 0 0 0.4 8
1 20 0 0 1.1 21.9
1 20 0 0 1.5 29.8
Total 100 1,988.2 74.9 1,489.2 25.1 499
Notes: percentages are taken from the SWAP report. Figures are rounded up.
Other than retail, hospitality and office wastes, the SWAP report does not provide
compositional data for the other commercial sectors presented in the SWMAL, i.e. wholesale
161

and education. Instead, reference was made to the Environment Agency’s Waste Benchmarking
tool which provides waste information on a sector by sector basis as described earlier in this
section. Whilst this data is not sufficiently detailed to allow an accurate estimation of waste
composition as for the sectors above, some insight can be gained. For both sectors, the Waste
Benchmarking tool suggests that, not surprisingly, paper and card, food, and plastics are
significant waste streams, as is wood for the wholesale sector. Sanitary wastes are not
insignificant quantities within adult and higher education.
It is acknowledged that the application of the SWAP report compositions to London as a whole
may not result in particularly accurate estimations. This is due to both the potential for
sampling error (as highlighted earlier in this section) as well as the fact that the SWAP report
was undertaken in Westminster and hence may not be applicable to London as a whole. Other
compositional surveys that we have accessed give significantly different figures for certain
categories; whilst these have been undertaken outside of London and are hence inapplicable,
they do demonstrate the danger of trying to apply one survey to a different situation.
Nevertheless, the estimates calculated in the above tables enable some conclusions and
recommendations to be drawn.
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Appendix E: Local Authority C&I Collection and Disposal Survey
Approach
Consultation by questionnaire was deemed to be the most appropriate approach. This was due
to the relatively large number of authorities involved and the desire to standardise replies to
assist in the efficient interpretation of results.
A draft questionnaire was developed. This was based on our review of existing information and
preliminary meetings with two of the boroughs (a unitary authority and a waste disposal
authority) which gave us the opportunity to discuss issues in greater detail. This draft was then
split into three separate questionnaires targeted respectively at the waste collection authorities
(WCAs), waste disposal authorities (WDAs), and unitary authorities (UAs).
The draft questionnaire was also reviewed in consultation with the GLA to ensure that it
addressed the issues of most interest and avoided duplication with other studies. The latter
particularly applied to the annual DEFRA/GLA municipal waste management survey.
The final versions of the questionnaires were agreed with the GLA on 6th April. They were
dispatched by Email to the relevant authorities using a contact list supplied by the GLA. The
questionnaires were sent to all the relevant authorities (i.e. 4 joint waste disposal authorities,
12 unitary authorities and 21 waste collection authorities) on 7th April 2004. Replies were
requested by Friday 16th April to enable results to be presented at the interim RTAB meeting.
Reminders were sent out during and after this period. Replies received after this date have also
been analysed.
Analysis
A total of 37 questionnaires were sent out, with 22 being completed and returned to SLR by
7th May. Responses were received from 11 of the 21 WCAs, seven of the 12 unitary UAs and
all four of the WDAs (Table E1). This represents an overall response rate of 60%. The short
timescale has prevented further responses from being obtained, as some boroughs were unable
to devote time to questionnaires at a time in the year when budgets and contracts for waste
disposal for the new financial year are being prepared.
Table E1: Local Authority Respondents to the Waste Questionnaire
Waste Collection Authority Unitary Authority Waste Disposal Authority
Barnet Bromley East London Waste Authority
Brent Corporation of London North London Waste Authority
Enfield Croydon
Harrow Southwark
Hammersmith & Fulham Sutton
Havering Tower Hamlets
Hounslow Westminster City Council
Islington
Redbridge
Waltham Forest
Wandsworth
163
Western Riverside Waste
Authority
West London Waste Authority

The findings are presented below. We have split our analysis into separate sections on waste
collection, waste disposal, trends and management systems. Responses have been aggregated
or otherwise presented in a manner to ensure confidentiality.
Waste Collection
A total of 18 out of 33 authorities responded to the questionnaires on waste collection. This
comprised 11 of the 21 waste collection authorities (WCAs) and seven of the 12 unitary
authorities (UAs) responded to the questionnaire.
The first group of questions asked about the collection of commercial and industrial waste.
DSOs were the preferred approach, with 11 of the 18 respondents using DSOs to collect wastes.
However, DSOs were more highly favoured in our returns by WCAs (six out of 11 replies) than
by UAs (two out of seven replies). Instead, the UAs preference was to use private waste
companies (five out of seven replies) compared to the WCAs (three out of eleven replies). Of
the remaining WCAs, one had externalised the collection (i.e. sold it to a private company) and
one had set up a joint venture.
Those authorities that used an external company to collect commercial and industrial waste
were asked to name the company. This applied to five UAs and three WCAs. The majority (six
out of eight) of the authorities used private companies to collect commercial wastes only, whilst
the remaining two (both UAs) used them to collect both commercial and industrial. Of our
sample returns, all but one of the authorities to whom this question applied used a single
company; the reaming authority (a WCA) used two different companies, but interestingly both
were for commercial wastes only.
Of the nine private waste contracts for waste collection in our sample returns, three were let to
Cleanaway and three to Onyx, two to MRS Environmental Services and one to BIFFA. Our
sample returns are not really sufficient to identify whether some companies are favoured more
than others, although our returns suggest that there was no clear favourite for the WCAs with
the each of the four contracts being let to a different company. For the UAs, two of the
contracts were to Cleanaway and two to Onyx, with one to MRS.
Of the nine private waste contracts, our sample returns suggests that the UAs had longer term
contracts in place as illustrated in Table E2. The longest term contract in our sample was for
the one WCA that operated a joint venture. The renewal date for this contract is 2015.
Table E2: Date of Renewal for Private Waste Collection Contracts
Date of Contract Renewal WCA UA Total
2004 3 - 3
2005 1 1 2
2006 - - -
2007 - 1 1
2008 - 1 1
2009 - - -
2010 - 2 2
Totals 4 5 9
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All of the respondents said that they would continue using their present collection
arrangements for commercial and industrial wastes in the future.
The next group of questions related to how the wastes are collected and handled. The first
question looked at whether commercial and industrial wastes are collected as a separate waste
stream or mixed with household wastes. Four of the 17 respondents practiced a high degree of
segregation with collections being always or mostly separate from household wastes. A greater
proportion (ten out of eighteen) collect always or mostly as mixed waste streams, with a further
three doing this around half of the time. The distribution of responses was similar between
WCAs and UAs for this question.
With regard to the collection of industrial wastes, just under half of the respondents (eight out
of 18) confirm that they do collect industrial waste (three UAs and five WCAs). An additional
WCA also said that they possibly do. In all cases, this was as a mixed collection from
manufacturing processes, factories and small scale operations such as workshops and
laboratories.
The authorities were asked if commercial recyclables were collected by or on behalf of the
WCA/UA. Of the 15 authorities who answered this question, only four collected commercial
recycleables (two WCA and two UAs). In all cases this was as a separate waste stream. One
respondent added that the material collected was cardboard. The remaining 11 respondents
did not collect commercial recyclables at all. Three of the authorities gave no response to this
question.
In terms of the nature of the data held in terms of waste collection, the authorities, were asked
three questions relating to whether they do or could break down the commercial and industrial
waste arisings by customer type, customer size and composition. Their responses are
summarised in Table E3 below.
Table E3: Ability of responding WCAs and UAs to provide a breakdown of
waste arisings that they collect by customer type, customer size and
composition
Can you provide a breakdown by: customer
type?
Yes – this analysis is currently
undertaken
Yes – this analysis could be undertaken
but is not at present
No – data could not be broken down in
this way
customer
size?
By
composition?
1 0 1
3 3 4
13 14 12
Totals 17 17 17
Note: one respondent (WCA) did not answer this question
From E3 it can be seen that only one authority (a UA) undertakes analysis for customer type
and of arisings by composition at present. A further three authorities have the ability to
undertake analysis by customer type (one WCA and two UAs) and size (one WCA and two UAs)
and four (one WCA and three UAs) by composition, but they do not currently do so. The
majority could not provide this breakdown.
The authorities were asked whether any waste handling and disposal facilities were operated by
the authority (either directly or under contract) excluding civic amenity sites. Five of the 18
165

authorities did operate a facility; these were UAs who each operated a waste transfer stations.
Two of the five waste transfer stations were on the river (Northumberland Wharf and Walbrook
Wharf).
The collection authorities were then asked about how waste is transported. Of the 17
authorities that answered this question, over half (i.e. 13) used exclusively diesel fuelled lorries.
(8 WCAs and 5 UAs). However, four authorities used alternative fuels to a greater or lesser
extent as follows:
• One WCA used exclusively LPG fuelled lorries.
• One UA used up to 25% LPG and remainder was diesel.
• One UA had up to 10% of its wastes transported by a combination of LPG and
battery fuelled vehicles.
• One WCA used up to 5% of vehicles fuelled by LPG.
Respondents were then asked to provide information on waste tonnages for commercial and
industrial wastes collected within their borough in 2002/3. Two authorities did not answer this
question. The information is summarised in Table E4 below.
Table E4: Tonnages of Commercial and Industrial wastes collected by
responding London Local Authorities
Authority Minimum Maximum Average Median Totals
WCA 600 28,544 14,209 14,280 127,885
UA 8,000 141,349 45,941 22,000 321,588
Totals 600 141,349 28,092 16,612 449,473
Base: this question was answered by 16 authorities (nine WCAs and seven UAs)
From Table E4, it can be seen that the Authorities that we surveyed collect just under 450,000
tonnes of commercial and industrial wastes. Just over two thirds of this was collected by the
UAs and just under a third by the WCAs. Our survey results suggest that the commercial and
industrial wastes collection services operated by the WCAs are of a much smaller scale than
those operated by the UAs; the WCAs have a lower range, a lower average and a lower median.
Of those authorities that collected industrial as well as commercial wastes, most respondents
provided a combined total to the question on tonnages. Therefore, it was not possible to
provide a breakdown between commercial and industrial wastes from a tonnage perspective.
This question also asked for tonnages for materials for recycling and composting. Just one
authority (UA) gave a recycling figure of 3,129 tonnes whilst a WCA noted that they collected a
negligible amount which was not measured separately.
The questionnaire then proceeded to ask authorities if they could estimate how much of the
total commercial waste arisings collected for or on behalf of the WCA for non-household wastes
could fall into the categories in the table below. A number of the authorities were unable to
provide approximate proportions of these commercial wastes, with eight giving no response to
this question. Five were able to provide data, with the majority of wastes coming from offices,
hotels and retail premises for most of these respondents. However, one authority only gave a
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proportion of waste collected from markets and fairs, and another collected the majority of its
commercial wastes from Local Authority and Government buildings.
Table E5: Analysis of commercial and industrial waste arisings collected by
responding local authorities by sector
WCA 1
WCA 2
WCA 3
WCA 4
Offices 38 25 * 40 0 30 * 48 45
Hospitality 15 30 * 10 0 30 * 24 35
Retail 40 35 * 40 0 40 * 19 18
LA / Gov’t 5 5 0 5 95 0 * 5 0 1
Parks 0 1 0 1 0 5 0 0 * 2 0.5
Markets 0 1 5 0 0 1 0 0 2.6% 4 0.1 1.5
Others 2 2
WCA 5
UA 1
UA 2
UA 3
0 1 0 0 1 5 3 0 * 1.9 0
Notes:
Base: nine respondents.
Offices: private offices and businesses etc. Hospitality: hotels, pubs, clubs, catering etc.
Parks: municipal parks and gardens.
*: No data provided.
1. No answer provided; assumed to be 0 from checking other results.
2. Identified by respondent as garages and other miscellaneous industrial premises
which are small operations.
3. Identified by respondent as waste from street trading.
4. Percentage calculated from data provided by respondent.
Whilst there is considerable variation between the authorities, the above table allows us to draw
some findings. In most cases the major sectors in terms of proportion are offices and retail
followed by hospitality. The exception is a WCA which was 95% from local authorities and
government buildings. Four authorities collected [relatively small proportion] of wastes from
markets and fairs. The relatively small number of respondents precludes aggregating the data
or undertaking further analysis.
The authorities were asked how the figures that they provided in the questionnaires were
determined. The findings are presented in the following table.
Table E6: How are the figures for commercial and industrial wastes that you
have provided determined?
Authority WCA UA Totals
Separate collection and weighbridge 0 1 1
Mixed collection and based on recent local
survey(s)
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2 3 5
UA 4

survey(s)
Mixed collection and based on another
authority’s/national survey
2 0 2
Other (please specify) 4 1 5
Totals 8 5 13
Base: thirteen authorities answered this question.
Only one authority was able to use the most accurate method for determining figures, i.e.
separate collection and weighbridge. Five authorities used a local recent survey undertaken in
their own authority, whilst two used surveys from other authorities. Five used other methods:
two were estimates, one was an approximation based on customer type, one was part separate
collections and weighbridge and one was a combination of survey and calculations.
The final question relating to waste tonnages asked authorities to provide approximate
tonnages on wastes that are of commercial or industrial origin but that are included in
household waste figures. Ten of the 18 respondents did not answer this question or did not
have information available. The remaining answers were considered too variable to usefully
include in this report.
The authorities were asked about their views regarding which approach (i.e. DSO, private waste
companies, externalised or other) to collection gave the most beneficial service in terms of most
cost effective service, clean local environment, changes in demand and changes in legislation.
Nine respondents chose ‘don’t know/can’t say’ or did not answer this question. Most of those
who answered did so in accordance with their authorities’ current approach to waste collection.
There were three interesting exceptions:
• A unitary authority that currently used private waste companies who identified that
an externalised service would be most likely to provide the greatest ability to
respond to changes in legislation;
• A WCA with a DSO service suggested that a private waste company would be the
most beneficial for changes in demand.
• A WCA with a DSO service was not able to say which would provide the best service
for meeting changes in demand or legislation (whilst they did identify the DSO as
providing the most beneficial approach for the cost-effective service and clean local
environment).
This question generated several comments. Two unitary authorities indicated that all these
factors are determined by the service specification, contract and client/contractor relationship.
One WCA stated that the DSO model has the potential to be the most cost-effective as there is
no need to make the degree of profit demanded of private companies by their shareholders.
The same respondent also considered the DSO to be the most flexible option and therefore
most likely to secure a clean environment and be most responsive to changes in demand, local
requirements and legislation. Another WCA commented that there was a need for “more
cohesion and co-ordination possibly London wide; the patchwork approach is not efficient in
economic or environmental terms and can impede infrastructure development.” Another WCA
noted that their answers to this question could change when WETS is introduced. Finally, one
WCA suggested that the “BPEO could well be that the WCA is required to arrange to collect all
commercial wastes free of charge for as standard service.”
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Finally, the authorities were asked if construction and demolition wastes are collected by or on
behalf of the authority. Five respondents did not answer this question. Six of the authorities
who did answer (four WCAs and two UAs) do not collect construction and demolition wastes.
Of the seven authorities (four WCAs and three UAs) that did collect commercial and industrial
wastes, six collected from residential properties, three from commercial sources and two from
industrial.
Waste Disposal
All four of the waste disposal authorities (WDAs) responded to the questionnaire along with
seven of the 12 unitary authorities. Therefore, the baseline for this part of survey on waste
disposal is 11 authorities out of a total possible of 16.
All but one of the respondents (i.e. 10) use external companies to manage the handling,
treatment and disposal of commercial and industrial wastes on their behalf. The exception was
one of WDA who is not divested and uses a number of approaches:
• Operates three waste transfer stations itself with private sector haulage and
disposal;
• Uses private contractors for the removal and disposal of wastes from five civic
amenity sites operated by WCAs
• Directs some wastes to four private sector transfer stations; and,
• Uses private sector contractor for industrial end of life vehicles.
Eight of the respondents (five UAs and three WDAs) used a single contract to handle and
dispose of commercial and industrial waste. Two of the UAs used two private companies.
These 12 contracts were let to seven waste management companies, of which Cory
Environmental Ltd had four contracts, SITA had two and one each for Cleanaway, Onxy, Waste
Recycling Group, London Waste Ltd and Shanks East London. The size of our sample is
insufficient to confirm the overall trends, and whilst it does appear that Cory has the greatest
number of contracts it is interesting that most of the major waste management companies do
have at least one contract in London. There was a wide variety in contract dates
Of the twelve private waste contracts, our sample returns suggests that the WDAs have longer
term contracts in place as illustrated in Table E7.
Table E7: Date of Renewal for Private Waste Handling and Disposal Contracts
Date of Contract
Renewal
UA WDA 1 Total
2004 2 2 2
2005 1 1
2008 1 1
2009 1 1
2014 1 1
2015 1 1
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2016 3 3
2027 1 1
2032 1 1
Totals 9 3 12
Notes:
1. Excludes reply from one WDA which is discussed separately below.
2. Respondent put 2003/5 in their answer
The WDA that is not divested and not included in the above table uses 15 individual contracts
with 10 private companies: Shanks Waste Services Ltd, Waste Recycling Group Ltd, English,
Welsh and Scottish Railways Ltd, Surrey Waste Management Ltd, Generay Ltd, McGovern Bros
(Haulage) Ltd, Powerday Ltd, Ace Waste Ltd, Car Spares of West Drayton Ltd and Technowaste
Ltd. Four of these had contract renewal dates between 2007 and 2009, three were annual
contracts and the remaining eight were roll over contracts.
All of the respondents plan to continue using their current services for the future handling and
disposal of commercial wastes. However, the one WDA that is not divested noted that in the
long-term it expects to enter into a single long-term contract because of the joint waste
strategy being produced with the constituent WCAs due to the capital investment requirements.
The authorities were then asked how commercial and industrial wastes are handled. Eight of
the eleven respondents (six UAs and two WDAs) handle commercial and industrial wastes
always mixed with other wastes. One of the WDAs commented that this answer did not quite
fit how they handle fridges and end of life vehicles. The remaining four authorities (one UA
and two WDAs) sometimes or usually mixed commercial and industrial wastes with other waste
streams.
We then asked the authorities about the way that they transport commercial and industrial
wastes. Five authorities (three UAs and one WDA) use exclusively diesel fuelled lorries. Three
of the authorities (one UA and two WDAs) use exclusively river transport. One UA used a
mixture of predominately diesel fuelled lorries (>76%) with between 6-25% by boat. The final
respondent (WDA) had between 51-75% by rail and 26-50% by diesel fuelled lorry. One WDA
did not answer this question.
We asked the authorities to provide information on the total tonnages of commercial and
industrial wastes handled by or on behalf of the WDA and how much was from the WCAs and
other sources. Three of the four WDAs answered this question. One WDA only receives
commercial wastes from WCAs – a total of 690,426 tonnes. A second handles a total of
213,000 tonnes, of which 130,000 tonnes were from WCAs and 83,000 tonnes from other
sources. The third WDA handles a total of 32,500 commercial and industrial wastes but did not
specify whether this was solely from WCAs or included other sources.
With regard to the UA tonnages, it was assumed that they will dispose of all waste collected
within their authority. Since they had been asked for this figure earlier (see waste collection
section above), they were only asked if they handled commercial or industrial wastes received
from sources other than the authority. One UA received 2,826 tonnes of commercial wastes
from sources other than the authority. One UA wrote “unknown” which suggest that they do
receive some wastes from other sources but did not provide any tonnages. Two of the UAs did
not receive any wastes from non-authority sources. Three UAs did not answer this question.
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The authorities were asked how the figures provided had been determined. One UA confirmed
that this was from weighbridge figures whilst two of the WDAs figures were from their own
recent surveys and on WDA used both weighbridge and local survey. The remaining seven
respondents (five UAs and one WDA) did not answer this question.
In terms of the nature of the data held in terms of waste handling, the authorities, were asked
three questions relating to whether they do or could break down the commercial and industrial
waste arisings by customer type, customer size and composition. Their responses are
summarised below.
Table E8: Ability of responding UAs and WDAs to provide a breakdown of
wastes that they handle by customer type, customer size and composition
Can you provide a breakdown by: Customer
type?
Yes – this analysis is currently
undertaken
Yes – this analysis could be
undertaken but is not at present
No – data could not be broken down
in this way
customer
size?
by
composition?
0 0 0
2 2 2
8 8 8
Totals 10 10 10
Note: one respondent (UA) did not answer this question
It can be seen from the above table that only two authorities could provide further information
on customer type, size or composition, although this analysis is not currently undertaken.
These were both UAs. The majority could not provide this breakdown.
The authorities were then asked about their waste disposal facilities. They were asked how
many new treatment and disposal facilities had been built and are operational within their
Authority since 1986 (i.e. since the disbandment of the GLC). Seven of the respondents had
no new waste disposal facilities (three UAs and all four WDAs). Just one UA had a new facility
which was a composting plant. Also, one UA mentioned a riverside transfer station that had
been completely refurbished in this time. Two UAs did not answer this question.
The authorities were also asked about what new treatment and disposal facilities are currently
proposed within their boundaries. Five of the 11 respondents (four UAs and one WDA)
confirmed that no new facilities were proposed and one UA did not answer this question. The
facilities that are proposed are summarised below.
Table E9: What new treatment and disposal facilities are currently proposed
for the future within your boundaries?
UA Anaerobic digestion plant
UA A large PFI project to include specific treatment options
WDA Composting plant
WDA Four RRC and two MBT plants in construction
WDA Draft joint waste strategy shows a requirement for: 3 MRFs, 3 composting
plants, windrow capacity, MBT replacement facility for an energy recovery
plant
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The authorities were asked about their views regarding which approach (i.e. DSO, private waste
companies, externalized or other) to managing waste treatment and disposal gave the most
beneficial service in terms of most cost effective service, clean local environment, changes in
demand and changes in legislation. Four respondents (two UAs and two WDAs) chose ‘don’t
know/can’t say’ or did not answer this question. Only one of the respondents then answered in
accordance with how the authority operates (i.e. a WDA using private waste companies who
considered that using private waste companies was the most likely to provide the most
beneficial service). The other answers, which are all from UAs are follows:
• Respondent uses private companies and whilst saying that private companies were
the most likely to provide the most beneficial service for all issues, answered don’t
know/can’t say for changes in legislation and increased recycling.
• Respondent that uses private company and, whilst saying that private companies
were the most likely to provide a cost effective service and increase use of
innovative treatments, thought that a joint venture would be the most beneficial for
all other issues.
• Respondent that uses private company and whilst saying that private companies
were the most likely to provide a cost effective service, clean local environment,
meet changes in demand and increase recycling, thought that other options would
be more likely to meet changes in legislation (but no option specified) and that a
joint venture would be most likely to increase the use of innovative treatments and
decrease landfill. This respondent also added that the question was difficult to
answer with certainty until the full impact of the WETS legislation is understood.
• A respondent that uses a private company and who considered that both a private
company and a joint venture would be the most likely options to provide a beneficial
service for all issues.
• A respondent that uses a private company and, whilst saying that a private company
is the most likely to provide a cost effective service, clean local environment,
increase the use of innovative treatments and decrease landfilling, that a joint
venture would be most likely to meet changes in demand, changes in legislation and
to increase recycling.
This question generated several additional comments. One UA indicated that all these factors
are determined by the service specification and another that it would “depend on the
circumstances prevailing at the time and the willingness of the various parties involved to work
together constructively and pragmatically”. Another WDA commented that “these questions
are for the specific authorities to answer” and two WDAs that it depends upon many factors.
Trends
There next came a series of questions about the future trends of waste arisings. The first
question asked WCAs and UAs for their view on what will happen to total waste arisings in the
future. Five authorities believed that waste arisings will increase by more than 5% and six
believed that they would stay approximately the same. One authority had no view held on any
of the statements relating to future arisings and six did not answer.
The WCAs and UAs were asked for their view on the future arisings of biodegradeable matter
(excluding paper and card). Four responded that it would increase by more than 5% and seven
that it would stay approximately the same. One did not know and six did not answer.
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All authorities were asked how they expected the amount recycled to change in the future.
Four of the respondents had no view on this issue. Twelve believed that the amount of
recyclables will increase by more than 5% in the next five years compared to four who thought
it would not change. One did not know and five did not answer this question.
The WDAs and UAs were also asked for their views on how the amounts composted and
incinerated would change in the future. Six believed that the amounts composted would
increase by more than 5%. Two believed that the levels of composting would stay
approximately the same. Two did not know or could not say how composting levels would
change. One authority did not answer.
WDAs and UAs were asked about their views on the future of incineration with energy recovery.
Five thought that it would increase by more than 5% and three that it would stay approximately
the same. One did not know and three did not answer this question.
WDAs and UAs were asked about their views on the future of incineration without energy
recovery. Two thought that it would stay approximately the same and one that it would
decrease by more than 5%. Three said this question was not applicable to them and two did
not know. Three did not answer this question.
WDAs and UAs were asked about their views on the future of landfilling with methane recovery.
Two thought that it would increase by more than 5%, one that it would stay approximately the
same and four that it would decrease by more than 5%. Two did not know. Two did not
answer this question.
WDAs and UAs were asked about their views on the future of landfilling without methane
recovery. One thought that it would increase by more than 5% and three that it would
decrease by more than 5%. Two said that this question was not applicable to them and two did
not know. Three did not answer this question.
The UAs and WDAs were asked about whether they expected to use alternative forms of
treatment and disposal in the foreseeable future. Their answers are summarised below.
Table E10: Do you expect to use alternative forms of treatment and disposal in
the foreseeable future?
Yes Possibly No Don’t know 1
a) Treatment by gasification or pyrolysis 2 2 4 5
b) Mechanical biological treatment 3 2 3 5
c) Anaerobic digestion 2 3 3 3
d) Auto claving 1 3 2 8
e) Other (please specify)
Notes:
1. Includes did not answer.
2. One respondent stated that gasification/pyrolysis and/or mechanical biological
treatment may be used; hence this answer has been included in both categories.
3. Respondent stated that auto claving is already being used for clinical waste.
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From the above table it can be seen that anaerobic digestion and auto claving are the two
technologies that are definitely expected to be used (auto claving is already being used), whilst
it is possible that gasification, pyrolysis and mechanical biological treatment will be used in a
few cases.
The UAs and WDAs were asked whether they expected to meet the Landfill Directive
obligations for 2010 without the need to acquire additional allowances (i.e. to reduce the
amount of biodegradable municipal waste landfilled to 75% of that produced in 1995). Their
answers are summarised below from which it can be seen that the majority of the respondents
expect to meet their obligations.
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Table E11: Do you expect to meet the Landfill Directive obligations for 2010
UA WDA Total
Yes, definitely 1 - 1
Yes, maybe 4 2 6
No, probably not 1 1 2
No, definitely not - 1
Don’t know 1 1 1
Total 7 4 11
The UAs and WDAs were asked whether it is possible for the authority to treat and dispose of
the majority (approximately 80) of its wastes within their own boundaries. Their answers are
summarised below, from which it can be seen that three thought it was possible and eight
unlikely or definitely not.
Table E12: Would it be possible for the authority to treat and dispose of the
majority (80%) of its wastes within its boundaries?
UA WDA Total
Yes, definitely 1 - 1
Yes, maybe - 2 2
No, probably not 1 - 1
No, definitely not 5 2 7
Don’t know - - -
Total 7 4 11
The UAs and WDAs were asked whether it is possible for the authority to treat and dispose of
the majority (approximately 80) of its wastes within the Greater London area. Their answers are
summarised below from which it can be seen that the weight of opinion was a little more in the
positive than the negative.
Table E13: Would it be possible for the authority to treat and dispose of the
majority (80%) of its wastes within the Greater London area?
UA WDA Total
Yes, definitely 3 - 3
Yes, maybe 2 2 4
No, probably not 1 - 1
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No, definitely not 1 2 3
Don’t know - - -
Total 7 4 11
The UAs and WDAs were asked whether appropriate provision has been made within the local
plans for the future disposal of commercial and industrial wastes that are under the control of
the Authority. It can be seen from the following table that opinion is split between the five
authorities that thought appropriate provision had definitely or maybe been made compared to
the five who thought that it probably or definitely had not. One WCA answered don’t know.
Table E14: Has appropriate provision been made within the local plans for the
future disposal of commercial and industrial wastes that are under the control
of the authority?
UA WDA Total
Yes, definitely 2 1 3
Yes, maybe 2 - 2
No, probably not - 2 2
No, definitely not 2 1 3
Don’t know 1 - 1
Total 7 4 11
Local Authority Environmental Management Systems
All the authorities were asked about whether they had or were intending to develop an
environmental management system (EMS). From the following table it can be seen that half of
the respondents had or intended to develop an EMS and half do not. Only two have an EMS in
place at present, one of which is certified to EMAS and the other has no intentions to certify.
Six authorities did not answer this question.
176

Table E15: What is the situation regarding an environmental management
system (EMS) in your Authority?
WCA UA WDA Total
Operating an ISO 14001 certified EMS - - - -
Operating an EMAS certified EMS - 1 - 1
Developing an EMS with the intention
of certifying against ISO 14001
Developing an EMS with the intention
of certifying against EMAS
Operating an uncertified EMS – no plans
to certify against a recognised standard
No EMS, but planning to develop one in
the future
1 1 - 1 2
- - - -
1 - - 1
3 1 - 4
No EMS and no plans to develop one 4 4 - 8
Other (please specify) - - - -
Total 9 6 1 16
Notes:
Six authorities (two WCAs, one UA and three WDAs) did not answer this question.
1. The respondent indiciated that the EMS was being developed by the contractor.
All the authorities were asked about whether they had or were intending to develop a quality
management system (QMS). From the following table it can be seen that 10 of the 16
respondents had or intended to develop a QMS, whilst 6 do not plan to do so. Seven have
some form of system in place at present, three of which is certified to ISO 9002. Seven
authorities did not answer this question.
Table E16: What is the situation regarding a quality management system
(QMS) in your Authority?
WCA UA WDA Total
Operating an ISO 9002 certified QMS 2 1 - 3
Developing a QMS with the intention of
certifying against ISO 9002
Operating an uncertified QMS – no
plans to certify against a recognised
standard
No QMS, but planning to develop one in
the future
1 1 1 1 3
- - - -
3 - - 3
No QMS and no plans to develop one 1 5 - 6
Other (please specify) 1 2 - - 1
Total 8 7 1 16
Notes:
177

Seven authorities (3 WCAs and four WDAs) did not answer this question.
1. The respondent indiciated that the EMS was being developed by the contractor.
2. Four consecutive Charter Marks for the Department
178

Appendix F: Consultees for Construction and Demolition Waste
Waste Management Company/
Organisation
The Waste Regulatory Authority
Consultation/Response
The Environment Agency Telephone – qualitative information
Research Organisations/Consultants
Symonds Group re C&D Surveys Telephone – discussed survey results
BRE Telephone - qualitative information
SLR Consulting Ltd Meeting – qualitative and quantitative
information
London Remade re C&D Eco Centre Telephone – qualitative and quantitative
information
EnviroCentre re Demolition Protocol Telephone – qualitative information
Faber Maunsell re London Sustainable
Construction Project
London Development Agency re
Silvertown and Royals developments
Initiative/Tool Promoters
Telephone - qualitative information
Telephone – did not respond
London Sustainability Project Telephone – qualitative information
SalvoMie Telephone – qualitative information
Wastetraders E-Mail – did not respond
CIRIA Recycling Website Telephone – did not respond
Aggregain Telephone – did not respond
Trade Groups/Institutes
National Federation of Demolition
Contractors
Telephone – qualitative and quantitative
information
Institute of Demolition Contractors Attendance at seminars
Demolition Contractors
Keanes Ltd Meeting – qualitative and quantitative
information
Toureen Contractors Telephone – qualitative and quantitative
information
179

Syd Bishop Ltd Telephone – qualitative and quantitative
information
777 Demolition Telephone – declined consultation
General Demolition Telephone – qualitative information
Brown and Mason Telephone and e-mail – did not respond
Coleman and Co Telephone and e-mail – did not respond
Button Demolition Telephone – qualitative and quantitative
information
CDC Demolition Telephone and e-mail – declined
consultation
RC Demolition Telephone – unable to help before April
Bromley Demolition Telephone – declined consultation
Clifford Devlin Telephone and e-mail – did not respond
Tower Demolition Telephone –little work undertaken in London
Keltbray Telephone and e-mail – did not respond
Cantillon Haulage and Demolition Telephone and e-mail – did not respond
McGees Telephone – did not respond
Construction Contractors
Ardmore Construction Telephone – did not respond
Multiplex Telephone – qualitative and quantitative
information
Tilfen Land Telephone – did not respond
Birse Telephone – qualitative and quantitative
information
Contaminated Land Contractors
Envirotreat Telephone – qualitative and quantitative
information
Waste Management Companies
Erith Waste Management Telephone - qualitative information
SITA Telephone – did not respond
180

Appendix G: Policy, legislative and other measures influencing the high
recycling rates of C&D waste in Germany, Denmark, Belgium and
the Netherlands
181

Measure
Restrictions or bans on
disposal to landfill
Germany Denmark Belgium The Netherlands
• Ban on disposal of mineral
demolition waste & unsorted
C&D waste.
• Closed-Cycle & Waste Act gives
waste recycling priority over
waste disposal.
Taxes • No federal taxes applied to
disposal of C&D waste.
• There are different prices for
landfilling according to the
nature and composition (and
degree of hazard) of the
waste, which encourages
sorting of C&D waste.
Subsidies • No direct subsidies on C&D
waste recycling or re-use.
Voluntary agreements
(VAs)
• A national VA between
industrial organisations and
the government containing
• National waste management
policy requires minimisation of
landfilling and incineration of
C&D waste.
• Only waste which cannot be
recovered in an
environmentally safe way is
supposed to be landfilled.
• National tax on landfilling and
incineration since 1987.
(45ECU/t for landfilling)
• Taxation in combination with
other leglislation and planning
measures is cited as being
highly successful in reducing
landfilling of C&D waste to a
minimum.
• No direct subsidies on C&D
waste recycling or re-use.
• In 1996, a national VA on
selective demolition was
signed between the
182
• No legal restrictions or bans in
any of the three regions.
• Flanders has VLAREA
legislation (1998) banning
disposal of unsorted industrial
waste (includes most C&D
waste), thus C&D waste must
be sorted first.
• Brussels has indirect ban on
disposal through the order of
16 March 1995 regarding
obligatory recycling of certain
types of non-contaminated
C&D waste.
• Landfill charges and
environmental tax for C&D
waste to Class III landfill
(16ECU/t)
• Flemish government levies a
lower rate of tax on disposal of
final waste fraction of
processed C&D waste
(encourages sorting and
recycling).
• Companies which install
prevention of waste systems
under PRESTI (see education
and training below) can get
subsidies from the government
• Wherever possible Belgian
regions prefer voluntary
agreements and consensus
• Total national ban on disposal
of re-usable C&D waste since
1997.
• A levy system is applied to
landfills, which differs from
region to region, ranging from
23-90 ECU/t.
• The government offers
contractors for public works
the opportunity to earn
bonuses if they use secondary
aggregates (C&D wastederived)
instead of natural
gravel.
• In 1995, the government and
20 industry organisations
agreed on measures to prevent

Measure Germany Denmark Belgium The Netherlands
Pilot & demonstration
projects
targets for reducing disposal of
C&D waste, measures for the
government to make
information and advisory
services available to C&D
companies, and to undertake
research and development.
• Demonstration schemes have
been carried out on selective
demolition and the general
logistics of C&D waste site
management.
Education & training • Education and training is
included as a requirement
within voluntary agreements.
government and the
Association of Demolition
Contractors.
• Many pilot and demonstration
projects on C&D waste
recycling have been carried out
since the mid 1980s, including
projects on selective
demolition, using crushed
masonry in carparks,
construction of ‘recycled’
houses.
• Theoretical and practical
training on C&D waste
management issues are
available through Technical
Universities and Civil
Engineering Colleges.
183
objectives to regulation.
• Flemish government developed
the Implementation Plan for
C&D waste together with the
construction industry, the
main aim was to achieve 75%
recycling of C&D waste by
2000. This target was
exceeded, and modifications
to the Plan have begun with
an even higher recovery target.
• Many demonstration projects
carried out since the 1980s,
including large projects using
of recycled crushed concrete
aggregates in new concrete,
demonstrating use of recycled
materials in public works, and
establishing technical
specifications for higher grade
applications.
• PRESTI and MARCO
programmes raise awareness in
the C&D industry of
environmental issues (e.g.
noise, energy, waste).
• Flemish government produced
a brochure aimed at architects
about recent developments in
C&D waste prevention and
recycling, including demountable
construction and
and re-use C&D waste, this
was later incorporated into a
policy declaration.
• There have also been VAs
between waste contractors and
recycling companies, (e.g.
agreeing on separate
collections of glass).
• Pilot and demonstration
schemes have been
undertaken to demonstrate
the application of secondary
materials (e.g. soil and
dredging spoil, concrete,
masonry, mixed aggregates,
sieve sand, asphalt granulates)
in landraising, as sub-base
material, and coarse
aggregates in concrete.
• There is also a program
comprising at least 100
demonstration projects
promoting waste minimisation
by prolonging the life span of
materials.
• The Dutch government does
not operate any C&D waste
related education and training
programmes.

Measure Germany Denmark Belgium
selective demolition.
The Netherlands
Advisory services • Information and advisory • Two private sector institutions • National advisory service for • Advisory services regarding
services to be made available are provided with financial recycling in the construction prevention and re-use of C&D
to C&D companies is a
support to act as ‘know-how’ industry operated from 1994- waste are provided by
provision in voluntary
centres for C&D waste
1997. A separate service
commercial and not-for-profit
agreements.
recycling and disposal.
currently operates covering organisations.
recycling in road construction. • An internet-database with
waste minimisation and
separation measures for the
building sector is available,
plus reports of demonstration
projects and manuals for EMSs
for the building sector.
Waste exchanges • National and regional internet- • There is an active market for • Flemish waste agency operates
based waste exchanges
C&D waste in Denmark.
an internet-based waste
offering uncontaminated road Demolition contractors market exchange.
construction waste, concrete, re-usable demolition materials
bricks, crushed and uncrushed
natural stone, soil and wood.
from their own stock yards.
Positive waste planning
measures
• Regional authorities issue
guidance and information on
• High national recycling targets
for waste. Municipalities set
• Flemish Waste Decree (1981)
explicitly enables use of waste
• Government programme since
1996 aimed at the promotion
how to increase recovery of local targets in their waste materials as secondary raw of environmentally friendly
C&D waste.
management plans generally materials, the rules and
products in the building
• All demolition activities need
approval from the relevant
authorities.
•
following the national targets.
Municipalities responsible for
securing sufficient local
conditions for which were
defined in the VLAREA
legislation.
•
sector.
Ministry of Environmental
Planning published a
• German Waste Management treatment capacity for C&D • Flemish waste authorities must handbook for governmental
Act requires federal authorities waste, often involves the
develop implementation plans organisations providing
and other public agencies to municipalities setting up and directed at specific industrial practical measures and
use particularly durable, less- operating facilities themselves. sectors (e.g. Implementation instruments on the use of
polluting or recycled materials
Plan for C&D waste developed secondary raw materials.
in construction, demolition
and renovation of public
in conjunction with the
industry).
• Local authorities have many
instruments available to them
works. Guidance has been
to stimulate use of secondary
published by the Federal
raw materials, e.g. including
government for implementing
specific regulations into plans,
these requirements.
attaching conditions to
building permits.
184

Measure Germany Denmark Belgium The Netherlands
Good monitoring
systems
• Reliable monitoring system of
C&D production in place.
• Reliable monitoring system of
C&D production in place.
Mandatory reporting • Demolition permits required
with mandatory reporting to
authorities.
Standards & quality
assurance schemes
• Technical requirements are set
out for the use of recycled
• Danish Society of Civil
Engineers issued a standard for
• C&D waste crushers and
processors require a permit to
• The Dutch association of
demolition waste contractors
C&D waste in technical
the use of crushed concrete process waste and a certified (BABEX) set up a system of
documents.
and masonry as an aggregate Quality Assurance system. certification for its members in
•
•
•
Quality standards are set by the
Quality Association of
Construction Material
Recyclers.
Generally, secondary and
recycled materials have to
comply with the same
requirements as primary
materials.
Standard for demolition works
to define and describe
demolition activities.
material in new concrete.
•
Thus not only the waste
products have to fulfil
environmental conditions, but
the processing company or
system is also subject to
conditions.
Flemish recycling association
and the regional governments’
technical authorities initiated a
voluntary certification scheme
for recycled aggregates used in
unbound applications. COPRO
is the body responsible for the
certification of these
aggregates, and control of the
QA systems at the recycling
plants.
prescribing separate removal
and supply of C&D waste. A
similar certification system has
been set up by the equvalent
body for crushers and sorters
(BRBS).
• Subsequently, a national
technical standard was
drafted, to enable BENOR the
national standards agency, to
grant a quality label to C&D
derived aggregates.
Adapted from Symonds (1999)
185

Appendix H: Consultees for Hazardous Wastes
Hazardous Waste Forum
PF Ahern (London) Ltd
Port of London Authority
The Environment Agency
186