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UROC Skip to Resources Edition 19 September 2024
UROC Skip to Resources
Edition 19
September 2024
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The Journal dedicated to Independent Waste Operators
Edition 19
September 2024
www.uroc.uk
This issue is supported by
Contents
Welcome
Contents
4 Industry News
6 Materials Facilities
11 UK ETS
15 Profile: Beverley Bell
19 Health and Safety:
Loud & Clear
20 Feature: Green Compass
22 Wood Waste
24 Feature: KPMG
28 Opinion: Simon Ellin
Published by
UROC MEDIA
30 Saunders Street
Southport
PR9 0HJ
Tel: 020 7633 4500
Design and layout by
Ellen Foster
Printed by
Replica Print
Its show time!
We are looking forward to seeing you at RWM (UROC Stand
RS-F136) – we will be running drop-in legal surgeries throughout
the two days if you need any free legal advice! On Day 1 we will be in
the Environment Networking Hub at 4pm - Workshop: PAS:402 Waste
Resource Management – Specification for Performance Reporting. On
Day 2 we will be in the Materials Village at 12:45 talking about the WRAP
protocol for aggregates which is currently being reviewed and will transition into a new Resource
Framework. UROC is working with the Environment Agency to develop the revision, so we will
keep you posted as this progresses!
From 1st October 2024, there will be new obligations on Material Facilities for sampling and
reporting various waste types as part of the Packaging Extended Producer Responsibility scheme.
As the regulations are being broadened, they will bring a number of waste operators into scope. It
is important for operators to check if they need to notify the regulators and secure compliance with
the requirements (see page 7).
UROC contributed the consultation on the waste sector being brought into the UK Emissions
Trading Scheme which will apply to EfW. This is a huge step change for the industry and, in
our view, needs to be carefully managed on implementation to ensure the integrity of the Waste
Hierarchy is maintained (see page 11).
Former Traffic Commissioner, Beverly Bell CBE, provides some insightful advice about Operator
Licensing in respect of skip operators who are being told before Public Inquiries that they should
be operating on the more onerous Standard National Licences and not on Restricted – make sure
you have the right licence! (see page14).
There has been some great industry guidance issued on cement bonded asbestos (see page 4) and
wood waste dust (see page 22) and industry innovation from Loud & Clear Technology (see page 19).
It was marvellous to catch up with Jacqueline O’Donovan OBE now that she has moved to pastures
green after completing the sale of O’Donovan Waste Disposal Limited in a Sortera acquisition.
Jenny Watts
CEO, UROC
Our team
CEO: Jenny Watts
UROC Journal
copyright 2024.
Reproduction of this
publication in part or
in full is prohibited.
This journal has been
printed on paper from
a sustainable source.
Chair for England: Paul Needham
Chair for Scotland: Robin Stevenson
Chair for Wales: David Williams
Strategy & Development: Barry Dennis
Contact: network@uroc.uk | 07966234760
Over 99%
of waste wood collected
is recovered and recycled
into new products and our
award winning bedding.
The
Waste Wood
Experts
Wood Recycling
enva.com/wood
www.uroc.uk
September 2024 SKIP TO RESOURCES 3
Industry News
Windsor Waste Management explores the updated
guidance for the management of bonded asbestos
(cement) waste
In conjunction with the Environmental Services
Association (ESA), Windsor Waste Management looks
at new updated guidance released for the removal
and disposal of asbestos cement waste and what this
means for businesses involved in the process.
Regulations outline that asbestos waste needs to be suitably
and appropriately packaged and contained for transportation
and disposal. Practices such as ‘Enveloping’ (where asbestos
waste is bulked sealed using polythene within a skip/ container)
have become a widely used practice within the industry, despite
being non-compliant.
The ESA has been working with members, in a focus on
bonded asbestos cement waste, to address the inconsistencies
in standards and reinforce the criteria for the safe containment
and transportation of this waste stream. This will mean
practices will have to change for many companies disposing of
asbestos cement waste.
HOW DOES THIS AFFECT ME?
Loads arriving at landfill sites that are not appropriately
wrapped and contained, will be subject to quarantine and
investigation whilst the waste producer and waste carrier agree
on how to proceed. A grace period has been implemented
to allow organisations to adapt their practices to ensure they
meet the reinforced protocols; however, companies will need
to efficiently adapt their practices to ensure that asbestos
cement waste is accepted at disposal facilities and to ensure
that additional costs are not incurred through dealing with any
delays arising from non-conformance.
PREPAREDNESS
Businesses will now need to prepare when looking at their
asbestos cement removal jobs, ensuring they have a plan
in place for the appropriate and compliant packaging,
containment, and transportation of asbestos cement waste.
The bigger the job the bigger the impact. For instance,
for smaller asbestos cement jobs such as small roofing jobs,
businesses will need to ensure that they have the relevant
packaging materials and that they use an appropriate service
for the containment of the waste, either sealed enclosed skips
or containers or a van collection service from a licensed waste
management company. If the business has a waste carriers
licence it can also transfer the wrapped asbestos waste to a
permitted waste facility. For larger roofing jobs, certain practices
which are used by some businesses may need to be reviewed
and an appropriate solution sort for the removal and wrapping
of asbestos cement sheets.
ADVICE
Any business dealing with asbestos cement waste, should seek
advice from an experienced waste management contractor at
the earliest stages of their projects for guidance on the most
appropriate and cost-effective solution. This will help avoid
problems later down the disposal line and avoid the incurrence
of additional costs, through the potential non-conformance
issues arising at landfill sites.
Tony Windsor, Owner &
Founder of Windsor Waste
Management commented:
“This is an important step in
the right direction for the safe
containment and transportation
of asbestos cement waste. For
too long, lower standards of
containment and transportation
of asbestos cement waste have
become the ‘industry norm’
Tony Windsor, Owner &
Founder of Windsor Waste
Management
compared to the handling of other types of asbestos waste. The
waste management industry, working with the relevant trade
associations, is now stepping up to raise safety standards and
act on their Duty of Care to ensure asbestos cement waste is
transported and received safely and in line with the regulations.
We completely support this move and as a business with over
twenty years of experience operating in this industry, we can
support our clients to manage their asbestos waste compliantly
and efficiently.
The minimum standards for landfill sites receiving cement asbestos waste are:
• Smaller pieces of asbestos cement waste MUST be double bagged in UNapproved
packaging – A red inner bag with asbestos warnings and a clear outer bag
with appropriate labels
• Larger pieces of asbestos cement, such as roofing sheets MUST be double
wrapped in 1000-gauge polythene and labelled accordingly. It will no longer be
acceptable to line an open container to bulk seal asbestos cement waste.
• Only enclosed, lockable skips/containers MUST be used for transporting
asbestos cement waste. It is not acceptable to throw sheeting over a standard skip.
4 SKIP TO RESOURCES September 2024
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Industry News
Powerday embraces Zero Waste Week
Powerday is committed to
maximising recycling rates and
diverting waste from landfills
through their high-end materials
recycling facilities across London
and actively working to reduce
carbon emissions and support the
circular economy through closedloop
recycling programmes.
Since the beginning of 2024, Powerday
partnered with Protec which has led
to the remanufacturing of 51,388
ProplexRE sheets, saving 130 tonnes
of CO2 and diverting 196m³ of waste
from landfill. Similarly, their glass
recycling initiatives with Saint-Gobain
and McLaren has resulted in the
remanufacture of 40.3 tonnes of glass,
saving 48.4 tonnes of raw materials
and preventing 28.2 tonnes of CO2
emissions. These closed-loop initiatives
preserve natural resources by significantly
reducing the need for virgin materials.
Powerday is also playing a crucial
role in reducing waste and carbon
emissions by processing construction and
demolition waste efficiently and investing
in advanced technologies to convert
residual waste into renewable energy.
They recently deployed two Volvo FE
Powerday Permitted Facility
Electric Skip Loaders, powered by
renewable energy from their Willesden
plant. This project has already saved
approximately 35 tonnes of CO2
compared to a typical diesel skip lorry,
with estimated savings of 60 tonnes
by the end of the year, contributing to
cleaner air in London.
UK Construction Industry
According to statistics, the construction industry
generates 62% of the UK’s waste and 32% of all waste
sent to landfill. Crucially, 13% of construction materials
are diverted straight to waste without being used.
Q Flow undertook to review the UK construction industry
seeking to understand the state of waste management in
construction. An analysis of over 90,000 waste transfer notes was
undertaken to investigate the strengths within industry, as well as
areas for improvement.
INDUSTRY COMPLIANCE
How well does the construction industry comply with
the current legal requirements surrounding waste
management?
1 in 3 waste tickets are non-compliant.
The most commonly missing fields on waste transfer notes
(WTNs) were facility permits/exemptions, European Waste
Catalogue (EWC) code and carrier licence.
DIVERSION FROM LANDFILL
The current industry average rate for diversion from
landfill is 87%
Non-hazardous waste types that can be reused, recycled or
recovered are disposed to landfill in numerous cases. Examples
include soil and stone, mixed C&D and concrete wastes.
Non-compliance across all WTNs
Is a 100% Diversion From Landfill rate possible?
Achieving 100% waste compliance is possible but some
assistance is required.
CARBON
What is the carbon impact of all this waste?
Average emissions associated with waste transport per project
are over 9t CO2e; equating to more than 6,000 miles of waste
movements.
The current average carbon emissions associated with waste
management during construction is 190,000kg CO2e per
£1,000,000 project CapEx.
www.uroc.uk September 2024 SKIP TO RESOURCES 5
Legal
Materials Facilities: waste sampling
and reporting from October 2024
From 1 October 2024, more
materials facilities will need
to sample and report their
waste. Sampling and reporting will
be more detailed and more frequent
under the The Environmental
Permitting (England and Wales)
(Amendment) Regulations 2023.
THE AMENDED REGULATIONS
MAKE CHANGES TO:
• the type of facilities that must
meet the regulations and may
be required to sample incoming
and outgoing waste material
• the type of waste material
covered by the sampling
requirements
• the frequency at which
incoming and outgoing waste
material needs to be sampled
• the categories that incoming
and outgoing materials need
to be sampled, measured and
reported against
• the data that facilities must
record and report to the
regulator.
WHICH MATERIALS FACILITIES ARE
IN SCOPE
Many waste facilities will be required
to act under the regulations for the
first time. The amended regulations
bring into scope facilities which receive
single waste streams such as aluminium
cans or cardboard, and facilities which
consolidate waste material into bulk
quantities from multiple suppliers. You
will be required to self-assess whether you
are a Materials Facility (MF) under the
regulations.
Your facility (or part of a facility)
will not be considered a MF if:
• you only receive waste material from
a single supplier and do not separate
the material into specified output
materials
• local authority Household Waste
Recycling Center your facility solely
undertakes the processing or sorting
of waste electrical and electronic
equipment (WEEE), waste batteries or
accumulators.
• your facility solely undertakes the
processing and sorting of residual
waste.
The Environment Agency accepts
that Short-Term Domestic Skip Hire
operations are not in scope of the
amended Materials Facilities regulations
because they do not receive “waste
material” as defined in the regulations.
If any operator is carrying out other
activities on their site as well as shortterm
domestic skip hire, they will have to
assess whether that activity requires them
to consider their site or part of their site
as a Materials Facility.
What counts as waste material
• it’s from a household source or it’s
from a non-household source and is
similar to household waste in nature
or composition
• it was separately collected for the
primary purpose of preparing for
reuse or recycling.
• it’s a single kind of material (a single
stream) or multiple materials mixed
together (a multiple stream)
• it contains one or more material
types including glass, metal, paper,
card, plastic, or fibre-based composite
materials.
WHAT COUNTS AS SPECIFIED
OUTPUT MATERIAL
You may be producing ‘specified output
material’ if you sort the incoming waste
into separate waste material streams.
These outputs may include single or
EXAMPLES OF MATERIALS FACILITIES
Facilities likely to be considered MFs include:
• materials recovery facilities (MRFs) sorting household dry recyclables
• commercial and industrial waste facilities that receive waste material to
consolidate or sort into specified output materials
• waste transfer stations (WTS) that receive waste material to consolidate or
sort into specified output materials
• facilities receiving and sorting single streams such as paper and card
• facilities consolidating waste material received from two or more suppliers
into bulk outputs
Facilities not likely to be considered MFs include:
• facilities such as commercial and industrial MRFs that consolidate and
sort commercial and industrial wastes, unless the commercial waste meets
the definition of waste material
• MRFs or parts of MRFs sorting only residual waste (‘dirty’ MRFs)
• mechanical biological treatment (MBT) facilities, unless they accept
material that meets the definition of waste material and undertake MRF
operations on part of the site
• refuse derived fuel (RDF) including solid recovered fuel (SRF) production
facilities
• MRFs sorting materials from construction and demolition waste
6 SKIP TO RESOURCES September 2024
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Legal
Source: gov.uk
multiple streams and include: glass,
metal, paper, card, plastic and fibrebased
composite material.
Items that would normally be removed
before sorting the waste are not
considered specified output material – for
example, large or heavy items that could
damage sorting equipment or impact the
sorting process.
WHAT COUNTS AS A SUPPLIER
The following may be considered
suppliers to your facility:
• a waste collection authority (WCA),
including where the WCA outsources
their waste collection functions to
another organisation
• the operator of another MF who
transfers waste material to your facility
from their facility
• if not a WCA or an operator of
a MF, a person or organisation who
has collected the waste material and
delivered it to your facility
• if not a WCA or an operator of
a MF and the collector is not known,
a person or organisation who has
delivered the waste materials to your
facility.
WHEN YOU MUST NOTIFY THE
REGULATOR THAT YOU ARE A MF
If you are a MF, you must assess how
much waste material you are likely to
receive during the next 12 months.
Do this at the start of each 3 month
reporting period. The reporting periods
are:
• 1 January to 31 March
• 1 April to 30 June
• 1 July to 30 September
• 1 October to 31 December
As part of this assessment you must
consider the amount of waste material
received in the previous 12 months.
You must notify the regulator in writing
if you are likely to receive 1000 tonnes
or more of waste material in the next 12
months. Do this before the end of the
reporting period in which you made the
assessment.
INPUT SAMPLING, MEASURING,
AND RECORDING
• the total weight in tonnes of input
waste material for each supplier
during each reporting period
• the name and address of the supplier
(or of each supplier) for each batch of
material
• the date on which the batch of
material was received, from which a
sample has been taken
• its composition in relation to the input
sampling categories
• details of each supplier from whose
inputs the sample was taken
• total weight in kilograms of each
sample
• date the sample was taken
• details of the sampling methodology
used to take a representative sample
• the total number of samples taken for
each supplier
• the total weight of all samples
• Input sample size and frequency
An input sample must be taken for
every 75 tonnes of incoming waste
material received for each supplier in a
given reporting period.
The samples must meet the following
requirements:
• the minimum weight of each sample
is 55kg
• the average weight of all samples
taken should be at least 60kg
OUTPUT SAMPLING
If you need to conduct output sampling,
you must take samples of all the specified
output material produced during each
reporting period. Any outputs containing
multiple streams will also need to be
sampled.
The minimum sampling frequency and samples size for different material
ARTIFICIAL INTELLIGENCE
There are no restrictions to the use
of visual detection and recognition
technology for MF sampling. However,
it will remain the responsibility
of MF operators to measure, record and
be able to demonstrate to the regulator
how their sampling methodology
meets the regulations and produces
representative sampling results, whatever
technology is in use.
www.uroc.uk September 2024 SKIP TO RESOURCES 7
Legal
In association with
WHERE THE CIRCULAR ECONOMY TAKES CENTRE STAGE
In partnership with
FREE TO ATTEND
15 - 16 October 2024 | ExCeL London
ENABLING INVESTMENT INTO THE FUTURE
OF RECYCLING, REMANUFACTURING
AND ENVIRONMENTAL INNOVATION
COVERING ALL MATERIALS, FROM PAPER
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INNOVATIVE EXHIBITORS FROM ACROSS
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GET UP-CLOSE AND HANDS ON
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SCAN TO
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FOR YOUR
TICKET
8 SKIP TO RESOURCES September 2024
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Legal
Source: gov.uk
Source: gov.uk
www.uroc.uk September 2024 SKIP TO RESOURCES 9
Regulatory
10 SKIP TO RESOURCES September 2024
www.uroc.uk
Regulatory
Waste Emissions Trading
Scheme
The UK Emissions Trading
Scheme (UK ETS) replaced
the UK’s participation in
the European Union Emissions
Trading Scheme (EU ETS) on 1
January 2021.
The UK, Scottish and Welsh
Governments and Northern
Ireland Department of Agriculture,
Environment and Rural Affairs
– collectively making up the UK
ETS Authority – established the
scheme to increase the climate ambition
of the UK’s carbon pricing policy,
while protecting the competitiveness
of UK businesses. The UK ETS is
established through The Greenhouse
Gas Emissions Trading Scheme Order
2020.
may obtain ultra-small emitter status.
They would not be required to hold a
permit but are still required to monitor
and must notify their regulator if they
go over the threshold.
CONSULTATION
A consultation seeking input on a
number of proposals to expand the
scheme to include energy from waste and
waste incineration closed in August 2024.
UROC engaged extensively with the Department for Energy Security and Net
Zero (DESNZ) along with other key stakeholders.
DESNZ presented four broad objectives it hopes to achieve:
INSTALLATIONS
The UK ETS applies to regulated
activities which result in greenhouse
gas emissions, including combustion
of fuels on a site where combustion
units with a total rated thermal
input exceeding 20MW are operated
(except in installations where the
primary purpose is the incineration of
hazardous or municipal waste).
HOSPITALS AND SMALL EMITTERS
(HSES)
There are simplified provisions for
hospitals and also installations with
emissions lower than 25,000t CO2e
per annum, and where the installation
carrying out the activity of combustion
has rated thermal capacity below
35MW. These installations will be
subject to emissions targets instead of
having allowance surrender obligations.
ULTRA-SMALL EMITTERS (USES)
If eligible, installations with emissions
lower than 2,500t CO2e per annum
www.uroc.uk September 2024 SKIP TO RESOURCES 11
Regulatory
What this will look like for an EfW Operator?
UROC CONSULTATION RESPONSE
There has been limited engagement
on the topic of inclusion of Energy
from Waste (EfW) in the UK Emissions
Trading Scheme (ETS) from the UROC
membership, but in general UROC
is supportive of the inclusion of EfW
in ETS as an important part of the
UK’s efforts to decarbonise waste,
provided that the industry concerns are
appropriately addressed.
The proposals are viewed at a
high level as simply a future tax on
disposing of waste for recovery at EfW
facilities, which operators will have to
accommodate within their pricing, but
should achieve the desired effect of
increasing recycling and moving up the
waste hierarchy.
The UROC membership is faced
with the same issues as the waste
12 SKIP TO RESOURCES September 2024
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Regulatory
DESNZ considers there are challenges in implementing the policy which were included in the consultation:
majors and local authorities in that
the composition of waste is likely to
change in the next 3-5 years because
of the ongoing mix of legislative
reforms e.g., Simpler Recycling, Deposit
Return Scheme, Extended Producer
Responsibility, plastics tax, and impacts
from Persistent Organic Pollutants.
This makes investment decisions into
systems to remove plastic more difficult
because the percentage of plastic in
the waste steam is likely to change
in the short to medium term. Thus,
UROC strongly advocates for a phased
approach, starting with the introduction
of monitoring only with the aim of
benchmarking market indicative costs
to facilitate preparations, followed by an
initially simple implementation period
using emissions factors.
Except in some exceptional cases, it
would be neigh on impossible for UROC
members to pass back ETS costs onto
individual commercial customers based
on their specific waste profiles because
of the sheer number of customers (in
the many hundreds of thousands) and
the difficulty of sampling waste in a
meaningful and consistently accurate way
at this volume.
Therefore, any charges for EfW ETS
costs will need to be applied in a generic
manner to customers and a way will
need to be found by UROC members
to make those costs stable, as customers
only budget for costs to change annually.
Predictability & simplicity of costs is
essential for the smooth operation of the
market.
UROC does not believe that it will be
practical for EfW facilities to create a
bespoke ETS cost for each waste carrier
based on the fossil carbon content of
waste delivered. Sampling is practically
difficult, prone to inaccuracy as waste
compositions fluctuate and will likely
incentivise manipulation to minimise
charges by those wishing to game the
system. This will cause downstream
disruption in the waste market and
significantly complicate negotiations
between UROC members and EfW
operators.
The situation outlined above strongly
favours the use of a single waste fossil
carbon factor to be applied per tonne of
waste delivered to EfW sites when the
scheme is launched.
As happened with landfill taxes,
increases in waste costs should drive
consumers to focus more on moving
up the waste hierarchy and it will be
in operators interests to encourage
customers to make sure that film and
other plastics are collected as part of
the governments package of reforms
to reduce waste, ensure more easily
recyclable packaging is put into the
marketplace and to drive increased
recycling rates.
Signalling that in future more granular
assessments of the fossil carbon content
of the waste of individual operators may
be an option, should also encourage
particular attention on efforts to increase
the volume of plastic presented for
recycling by UROC members customers.
Once the impact of the legislative
reforms has had time to be fully realised
and the cost basis of ETS for EfW has
been established, UROC members will
also be in a better position to make
investment decisions in other approaches
to decarbonise, such as additional waste
sorting and processing.
It is also important to note that the
waste market is very sensitive to disposal
prices so if landfill or waste export is
made relatively cheaper because of the
impact of ETS on EfW, waste will likely
be diverted to these disposal routes, unless
policy is fully aligned and in good time to
ensure anti-leakage measures are in place.
There is also potential that ETS for
EfW will act as a stimulant for criminality,
in respect of illegal waste disposal, thus
all other things being equal, it will be
important not to ignore that impact from
the inclusion of EfW in ETS.
www.uroc.uk September 2024 SKIP TO RESOURCES 13
Legal
14 SKIP TO RESOURCES September 2024
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Legal
OPERATOR LICENCES –
Do you have the correct one?
Beverly Bell CBE is a transport consultant and qualified lawyer, but prior to this she was
the Senior Traffic Commissioner for Great Britain and called many skip operators to appear
before her at Public Inquiries. In this article Beverly provides an insight into the current views
of Traffic Commissioners (TC’s) in relation to the skip hire sector.
LICENCE TYPES
If you are reading this article chances
are you have an operator licence and
you probably don’t give it much thought
– until it goes wrong! I want to help you
prevent this and explain why you might
need to look at the colour of the discs in
your vehicle windscreens.
You may have a restricted licence
(orange discs) or a standard national
licence (blue discs) but what’s the
difference and how do you know if you
have the right one? Your licence disc tells
the world that you are trusted by your
Traffic Commissioner that your vehicles,
drivers, and other road users are safe and
that you operate on a level playing field.
Restricted means you can only carry
your own goods and standard national
means you can carry your own goods
and those belonging to other people. You
It is becoming more
common that TC’s
are requiring skip
operators to hold a
standard national
and not restricted
licences
need less money (financial standing) for a
restricted licence than a standard national
and restricted licence holders don’t need
to have a qualified transport manager.
TRANSPORT MANAGER
The transport manager is there to ensure
your drivers comply with the drivers’
hours rules, that your vehicles are safely
maintained and that your drivers always
do a proper daily walk round check and
report any defects. This last one is a real
challenge as it’s the most common cause
of the Driver Vehicle Standards Agency
(DVSA) taking vehicles off the road and
you don’t want it to be one of yours!
Good transport managers are not easy
to find or cheap to employ but they are
worth their weight in gold.
SKIP OPERATORS
I was surprised by the number of skip
operators who appeared at public inquiry
hearings, and I am sorry to say this
number is still far too high so why is this?
I think there are two main
reasons – ignorance of the rules and
misunderstanding of the law. Skip
operators can’t be expected to know
all the rules that govern their operator
licence and are not specialised transport
law experts.
TCs have tried to educate operators by
promoting training for operators and they
often ask them to attend a one-day course
(OLAT - which can be done online) that
explains their licence responsibilities. Take
the time to attend one of these as it will
open your eyes to what is needed and
show you how to do it properly.
GUIDANCE
It is becoming more common that TC’s
are requiring skip operators to hold a
standard national and not restricted
licences as they take the view that skip
companies are paid to transport third
party goods (your customers’ waste). In
the past the skip industry has said that
because ownership of the waste transfers
to the operator upon collection of the
skip, they are carrying their own goods
and only a restricted licence is needed.
But TC’s are often taking the view this
ignores the fact that, if a company is
carrying the goods for hire or reward,
who they belong to during that journey
is irrelevant. In one of the Guidance
Documents, they distinguish between two
types of skip operation: those where some
processing takes place and those where
transport from collection to delivery is the
sole or predominant service provided. The
former type of operation may qualify for a
restricted licence.
Their current Guidance considers
how much processing takes place when
deciding what type of licence is needed
and that if the transport of the waste is
ancillary to processing, then a restricted
licence may be sufficient. The operation
of a waste site under an environmental
permit where waste processing takes
place would be an indicator that the
www.uroc.uk September 2024 SKIP TO RESOURCES 15
Legal
transport aspect of the business might be
ancillary.
I hope this explains the TC’s approach
to the skip hire sector. For those (often
small) operators where the predominant
or only part of the operation is the
transport of waste in skips (where the
processing of the waste is done by
others), TC’s are very likely to say that
a standard national licence is needed,
although they consider each application
on a case-by-case basis.
APPLICATIONS, RENEWALS &
REVIEWS
TC’s are concerned about existing
restricted skip operator licence holders
having an unfair advantage over new
applicants, so when restricted licence
holders apply for their licence renewal
at the five-year stage, they are now asked
the same questions as new applicants.
The TC’s consider this will phase out
restricted licences being granted so
that all skip operators eventually have
standard national licences and there will
be a level playing field for all. By that
time, they say that only companies whose
transport operations constitute a small
part of a wider business will be able to
retain their restricted licences.
If operators come to a TC’s attention
for compliance reasons, they will also
review whether a restricted licence is still
appropriate and, if not, they will give
them time to apply for a new standard
national licence.
ADVICE
So, should you be worried if you need
to apply for a standard national licence?
My view is that you don’t as there is
far less chance of having operator
licence problems if you have a qualified
transport manager. It really is an
investment in your overall compliance
arrangements as well as being a lot
cheaper than the alternative!
Operators being called to a public
inquiry hearing may be great business
for me, but it is not for you. Expert legal
advice and representation fees (it is a
foolish or brave operator who attends
the hearing without), the sleepless
nights, the worry of what might happen
and the damage to your business
The operation of a
waste site under an
environmental permit
where waste processing
takes place would be an
indicator that the transport
aspect of the business
might be ancillary.
reputation are much more expensive
than getting it right in the first place.
Operating without a transport manager
is false economy.
Taking good advice and having some
training now so you don’t come to
DVSA’s attention really does save costs
and worry in the long run. Ringing your
customers to say you can’t collect or
deliver a skip because some examiner
has taken your vehicle off the road is not
great for customer relations!.
CHANGING THE WAY YOU MANAGE WASTE
• Nationwide Coverage
• Family Run Business
• Over 52 Years combined Waste Management
and Recycling Experience
16 SKIP TO RESOURCES September 2024
www.uroc.uk
Legal
YEAR
PARTNERSHIP
Supplying
the market’s
leading brand
for 20 years
BLUE-GROUP.COM
www.uroc.uk September 2024 SKIP TO RESOURCES 17
Health & Safety
18 SKIP TO RESOURCES September 2024
www.uroc.uk
Health & Safety
Regulatory Compliance and Enhanced
Safety Standards should be Loud+Clear
Who checks the critical checks?
In the daily operations of your business,
the performance of critical checks and
protocols is essential for maintaining a
seamless workflow, ensuring regulatory
compliance and crucially, ensuring the
safety and well-being of your workforce.
The key question concerns confidence –
how certain are you that critical processes
and checks are not only being properly
carried out at the correct time, but are also
accurately and efficiently documented?
A break through in safety
compliance
Step into a world where solutions are
practical, not complicated. Loud+Clear
Technology simplifies and delivers
straightforward solutions. In the journey
to achieving seamless operations
and unwavering safety, the ability to
demonstrate compliance, both legally and
ethically is a key focus in boardrooms.
The focus is not just safeguarding your
company’s reputation, avoiding penalties,
or building trust with stakeholders; but
embracing a culture of compliance that
becomes second nature to your business.
Unveiling the voice of safety
At the heart of industrial incidents and
the subsequent loss of production lies
human error—often stemming from a
lack of training or knowledge, stress,
fatigue, pressure, or complacency.
Imagine a solution born where realtime
verbal instructions mitigate risk and
improve operational efficiency. This is the
essence of Loud+Clear Technology.
Founder Ben Wilde, with a background
in medical science, conceptualised a voicebased
solution during a critical medical
event aided by a verbal defibrillator.
Together with Co-Founder Dan Hook,
a veteran in marine engineering and
technology innovation, they harnessed the
power of voice instructions to enhance
protocol adherence during crucial tasks
and emergencies.
The evolution of compliance and
safety
Through the power of voice,
Loud+Clear Technology’s products
introduce a new chapter in business
solutions. The secure cloud-based
Hub and AVA devices collaborate to
deliver voice-guided checklists and
procedures, demanding audio signoffs
for completion. The archiving of
these records in the Loud+Clear Hub
not only safeguards your workforce but
ensures the assurance of all operational
processes, swiftly resolving issues and
minimizing downtimes.
The AVA advantage
Picture this: a calm, guiding voice from
AVA devices, delivering immediate
verbal instructions across a spectrum
of situations, from industrial checklists
to critical processes. These batteryoperated
devices, equipped with WiFi
and cellular capabilities, are simple to
operate—requiring just a single button
push. Resistant to heat and water,
they seamlessly integrate into various
industrial settings.
Activations of the device are
intelligently stored in the Loud+Clear
Hub, providing compliance data at a
glance via a user-friendly dashboard.
Here, spoken words are transcribed
into reports, becoming a testament to
operational compliance. Bid farewell to
paper trails and tedious searches; the
Hub allows users to customise, monitor,
and update instructions, remotely gather
data, and assess checklist completion.
The scheduling functionality gives
managers and workers alike the
confidence that checks are being carried
out in line with operational guidance and
regulations. If an activation is missed or
does not complete for some reason, an
alert is triggered ensuring operational
decisions can be made and resolved
quickly, while recording the steps taken
for compliance purposes.
Full circle benefits
A real-time traffic light warning alerts
users and updates teams on necessary
actions, creating a full circle of
compliance and mitigating risk. With
up-to-the-minute data, businesses can
make informed decisions, instantly
accessing safety guidelines, streamlining
risk assessments, and bolstering
accountability.
A culture of safety
For team leaders, guaranteeing
procedural thoroughness and supporting
colleagues in executing complex tasks
becomes easy - protocols communicated
effortlessly to multiple sites with a click
on the Loud+Clear Hub, reducing manhours
and resource demands. Individual
empowerment takes centre stage, as
AVA devices allow direct issue reporting,
speeding up resolutions, enhancing safety,
and reducing the likelihood of errors.
Managers, equipped with real-time
reporting, have a compass pointing to
operational effectiveness or areas that
need attention. Loud+Clear Technology
becomes a cornerstone in simplifying risk
mitigation and compliance monitoring,
creating a culture that safeguards people,
culture, and business.
Pilot Sites
Embrace the future of safety compliance
with Loud+Clear Technology—a
solution designed to navigate the
complexities, ensuring your business
not only meets standards but sets new
benchmarks.
UROC members are invited to
participate in pilots to see how
this system can integrate into their
operations, by way of example, this
includes driver vehicle safety checks.
Contact: Ben Wilde
07737789614
benw@loudandcleartech.com
www.uroc.uk September 2024 SKIP TO RESOURCES 19
Feature
NEW ERA BEGINS FOR THE
GREEN COMPASS SCHEME
The Green Compass Scheme
has been operating throughout
the UK since 2015 and provides
the only means of gaining UKAS
accredited certification to ‘PAS:402:
Waste Resource Management –
Specification for Performance
Reporting’.
PUBLICLY AVAILABLE
SPECIFICATION (PAS)
PAS 402 was authored by BSI and
Constructing Excellence in Wales
providing a framework for certification
and becoming a mainstream requirement
in waste and resource management
audits throughout the UK.
Under the scheme, each waste and
resource management company report
their recycling, recovery and landfill
rates for a variety of waste streams.
These figures are then independently
verified by a UKAS Accredited
Inspection Body and help operators to
move up the waste hierarchy and secure
accurate reporting to regulators and
customers.
Green Compass membership is
applicable to waste management
organisations that process construction,
industrial, commercial or household
waste. Certificated operators include
all parts of the waste management
sector including companies who operate
transfer stations, materials recycling and
treatment facilities as well as disposal
sites.
Companies who are Green Compass
members are the elite of the waste
management industry and work within
the parameters of international quality
standards to demonstrate best practice
and endeavour to continuously improve
processes, delivery and customer
satisfaction.
WASTE AND RESOURCE OPERATORS
Waste management organisations that
are successful in their application to
become Green Compass members
are issued with an official certificate
of membership – and as part of the
commitment to continuous improvement
will need to be re-inspected every 12
months to maintain valid certification
and membership.
WASTE BROKERS AND DEALERS
Waste brokers and dealers are a vital
part of the scheme. Delivering a national
service at a local level, they can benefit
from links with Green Compass to
reduce the burden on due diligence and
supplier management. A Green Compass
member is pre-qualified through
the independent UKAS accredited
inspection – selecting a Green Compass
waste manager is an effective and assured
decision.
NEW SHAREHOLDERS
The scheme is on the brink of a new
era thanks to the financial support and
expert input from a number of new
shareholders:
20 SKIP TO RESOURCES September 2024
www.uroc.uk
Feature
Green Compass Managing Director,
Paul Jennings said, “The new
shareholders, all of whom have
longstanding interests in the resource
management sector, have joined forces
to provide financial backing to allow the
scheme to take major steps forward.
“The investment presents a huge
opportunity and with the active
support of the new shareholders we
are confident that PAS:402 will gain
the increased recognition that it merits,
and in a very short time will become
the standard by which the resource
management industry is measured”.
REVIEW
The Green Compass Scheme is now
sponsoring a review of PAS:402
and at the same time is undertaking
a complete re-design of the Green
Compass website to enhance member
benefits.
The review of PAS:402 will reflect the
significant changes that have taken place
in the last decade. The new website
will provide a far more efficient access
to membership for waste and resource
management companies who are
seeking to join the scheme.
CERTIFIED
There are many waste and resource
operators across Great Britain who are
already certified to include: Enva, Binn
Group, Collard, Glynn’s Skips, Potter
Group and Ron Smith Recycling, to
name just a few!
Williams a Williams cyf were proud
to be part of the original 10 companies
in the steering group for PAS:402 and
achieved the very first certification.
Managing Director, Meurig O Jones,
said, “We have always been committed to
the scheme and what it stands for. When
the chance came to be a shareholder
we had no hesitation in
committing to the scheme
and working with leading
industry experts.”
Powerday was the
first waste company in
England to achieve the
PAS:402 standard. John
Batteson, Senior Business
Development Manager
said, “Allowing companies
to understand what is
happening to their waste and
to increase recycling rates
and importantly to have
these performance reports
externally verified were
important factors in signing
up to the scheme.
“Further, Powerday
was introduced to Green
Compass and PAS:402
by an existing client, thus
demonstrative of how
important customers view
the scheme and the huge
benefits it brings to improve
waste practises and increase
recycling rates.”
Contact Green Compass
to find out more: Paul
Jennings 07703004420 /
paul@greencompass.org
www.uroc.uk September 2024 SKIP TO RESOURCES 21
Markets
Waste wood shredding Source: Wood Recycling Association
WRA launches first sector-specific
guidance on wood dust
The first best practice
guidance on wood dust
in the wood recycling
industry has been launched
today (September 3) by the Wood
Recyclers’ Association (WRA).
The ‘Wood Dust in the Wood
Recycling Sector’ document addresses
health and safety and sets out how
to prevent and control employee
exposure on sites, with a framework of
recommended measures.
Endorsed by the Waste Industry Safety
and Health Forum (WISH), the guidance
is the first of its kind specific to the
wood recycling industry, with current
Jamie Plevin, Managing Director, R Plevin
& Sons
HSE wood dust guidance focusing on
woodworking and construction.
WRA Board Member Jamie Plevin,
Managing Director at R Plevin & Sons
Ltd, led the project to develop the
guidance.
He said: “We are delighted to launch
this guidance today which sets out best
practice for businesses that operate in the
wood recycling sector on managing wood
dust from a health and safety perspective.
“We wanted to have a sector-specific
guide which recognises the nuances
of our industry.This will be a useful
tool to ensure everyone in the industry
understands their obligations and will
22 SKIP TO RESOURCES September 2024
www.uroc.uk
Markets
also help the HSE to understand our
sector better.
“Special thanks to the compliance team
at Plevin – Graham Hobson, Michelle
Barnes and Kevin Fletcher – without
whom this guidance would not have been
possible, and to Erica at the WRA for
her design work.”
Employers have a legal duty to protect
workers from the hazards of wood
dust under the Control of Substances
Hazardous to Health Regulations
(COSHH). They must carry out risk
assessments and take steps to ensure
risks are prevented or adequately
controlled. They must not exceed
certain Workplace Exposure Limits
(WELs) for dust and reduce employee
exposure to As Low As Reasonably
Practicable (ALARP).
The WRA guidance addresses the
HSE’s recommendations on managing
exposure to wood dust and sets out the
ways in which the risks can be prevented
or adequately controlled according
to a ‘hierarchy of control’. It covers
topics including risk assessments, wood
dust exposure during waste processing
activities, Respiratory Protective
Equipment (RPE) and health surveillance
of employees.
Chris Jones OBE, Chair of WISH,
said: “We welcome and support this
guidance which is the first ‘industrystandard’
document to be endorsed by
WISH and will be linked to from our
website.
“This will help employers in the wood
recycling sector to ensure they are
Personal Protection Equipment. Source: Wood Recycling Association
meeting their legal duties with regards to
wood dust and developing safe systems
of work.”
Julia Turner, Executive Director of
the WRA, said: “Health and Safety is
paramount in our industry and we hope
this guidance will help operators to
ensure they are following best practice.
“Thank you to Jamie and the team at
Plevin for all the time and expertise they
have dedicated to putting this guidance
document together.”
Waste wood shredding Source: Wood Recycling Association
TOOLKIT
Operators can use the WRA Toolkit for
a step-by-step guide to how to identify
amber material, take samples and send
them off for testing and also find a list of
approved WRA member laboratories.
Material should be tested according to
the WRA 02 testing suite but this does
not mean the results will automatically be
shared with the WRA, so operators need
to specifically tick the box confirming
their consent for their laboratories to
do this. There is no need to pay extra
to determine whether the material is
hazardous or not, unless you need this
information for another purpose, as
all results are analysed in-house by the
WRA.
Vicki added: “We are now seeing more
amber material being tested which is
really encouraging as the EA has asked
us for a monthly update to ensure we
meet the timelines set. Therefore, if you
are still unsure how to gain compliance
then please don’t hesitate to consult the
WRA Waste Wood Classification Toolkit
or get in touch with us directly.”
www.uroc.uk September 2024 SKIP TO RESOURCES 23
Mergers & Aquisitions
xxxx
Rosy Outlook for the Waste
and Resources Sector
William Griffith – Corporate Finance M&A at KPMG UK
Throughout 2023, UK
Mergers & Acquisitions
(M&A) activity levels were
significantly lower than expected
due to continued economic and
geopolitical headwinds, rising
interest rates, high inflation and
the cost-of-living crisis, which
prompted more caution. Tighter
credit conditions also led to a
higher cost of debt for those
seeking debt funding, and it has
driven lenders to be very selective,
operating with greater scrutiny.
However, for the UK’s Waste and
Recycling sector, it was an entirely
different picture, as the market
experienced growth across the
board.
William Griffith – Corporate Finance M&A at
KPMG UK
RESILIENCE
The Waste & Recycling sector
demonstrated great resilience over the
last 12 months, and while no sectors are
immune to macroeconomic conditions,
it has weathered the storm well as it is
viewed like an infrastructure investment.
As a result, M&A activity levels have
remained healthy despite the wider
economic and geopolitical challenges.
Looking at the sector geographically,
we’ve seen regionally-dominant
businesses which have demonstrated
growth through exceptional service
delivery, while a number of national
players have adopted acquisition
strategies to achieve their growth
ambitions.
FACTORS
Behind this growth, there are a number
of factors that have contributed, from
increasing UK waste tonnage and
24 SKIP TO RESOURCES September 2024
www.uroc.uk
Mergers & Aquisitions
CASE STUDY
Biffa’s acquisition of Hamilton Waste &
Recycling (HWR) is a recent case study which
is reflective of these themes and demonstrates
the appetite from buyers across various waste
streams, one of which being construction and
demolition.
HWR, a family-owned company incorporated in
2002, is one of the leading independent recycling
and resource management companies in Scotland,
processing over 135,000 tonnes of material annually. In
2021 HWR became Scotland’s first waste management
company to achieve 100% carbon-neutral status. It
diverts over 95% of incoming waste from landfill and
has invested over £10 million at its state-of-the-art
multi award-winning recycling centre at Smeaton, near
Edinburgh.
The acquisition of HWR is a significant step for Biffa,
expanding its waste capabilities in the construction and
demolition sector, further cementing its commitment
to low-carbon collections and material processing. Biffa
acquired the entire share capital and welcomed the 100
strong team at HWR into its collections business, along
with 49 vehicles and 1,400 new customers including
construction groups, restaurants, and local authorities.
an acute focus on recycling levels, to
Environmental Social Governance
(ESG), the circular economy and net
zero targets from stakeholders. All of
these have helped to create a prime
environment, supported by consolidation
which has driven strong levels of M&A in
recent years.
SUPPORT
At KPMG, our Advisory business has
been very active in the sector over the
last year, providing M&A services to
Hamilton Waste & Recycling and Forge
Recycling on their respective sales to
Biffa, and Enovert on their acquisition of
Highfield Environmental. The team have
also provided Due Diligence services
to Mick George on the sale to Hanson
(subject to CMA approval), Exponent
on the sale of Enva to I-Squared as well
as supporting Reconomy on multiple
acquisitions throughout 2023.
THEMES
There are two key themes which
are driving acquisitions in Waste &
Recycling. The first is the rise of private
equity investment into platforms to carry
out buy and build strategies using M&A.
Some examples include Beauparc, Biffa,
Enva, Reconomy, Sortera and Suez –
who each received significant investment
from Private Equity to support their
M&A strategies.
The second key theme is vertical
integration, which is essentially where
companies acquire within the waste &
recycling supply chain, demonstrating
circularity and helping large corporates
with Net Zero targets. Hanson’s
acquisition of Mick George (subject to
CMA approval) is a fantastic example
of this, and Simon Willis, Group CEO -
Heidelberg Materials UK, talked about
the acquisition promoting “circularity
and consequently recycling, reusing, and
thereby reducing the use of primary raw
materials” which is crucial to achieving
net zero. As a result, we are seeing lots of
competitive tension during sale processes
which is driving up deal values as
multiple parties are striving to put their
best offers forward.
OUTLOOK
Looking at the UK M&A market more
broadly, while dealmaking activity levels
have been somewhat supressed and the
cost of borrowing remains high, slowing
inflation is providing confidence that
better conditions can support successful
dealmaking.
The outlook for the Waste & Recycling
sector, however, is bright. The industry
is resilient in nature and there are some
exciting prospects that we are seeing,
with strong appetite from buyers for high
quality businesses across multiple waste
& recycling streams, including C&D,
commercial collections, food, plastics, oil
and industrial services.
Mergers and Acquisitions in the waste sector
www.uroc.uk September 2024 SKIP TO RESOURCES 25
Mergers & Aquisitions
First Mile acquires Redbridge Borough
Council’s Commercial Waste Business
First Mile, a UK based waste company, have acquired the commercial waste collection arm
of Redbridge Council, based in East London.
First Mile, who already operate
commercial waste collections
in Redbridge borough, took
over the council’s commercial
waste collections in August.
The acquisition has seen almost 1,500
trade waste agreements transfer over
to First Mile, including all trade waste
customers of Redbridge Council, across
localities such as Ilford and Woodford
Green.
The deal relieves the council of costpressures
to deliver a trade waste service,
whilst enabling their customers to
benefit from immediate access to over
50 recycling stream collections from
First Mile, previously only being able to
procure general waste services from the
council.
The move came at an important time to
help ensure businesses are compliant with
upcoming Simpler Recycling legislation,
which will mandate for separate food
recycling collection for most businesses
next year, which all Redbridge businesses
can now access through First Mile.
Joe Allen, Chief Commercial Officer at
First Mile said “We are thrilled to have
completed this purchase and to welcome
Redbridge customers to First Mile. We
look forward to helping businesses recycle
and ensuring we deliver hassle-free
service to businesses across the borough”
Cllr Jo Blackman, Cabinet Member
for Environment and Sustainability
at Redbridge Council said “First Mile
Limited were chosen after an extensive
evaluation process. Due to ongoing cost
pressures, we were happy to find a buyer
who could help our business customers
comply with upcoming legislation, and
support them with high service levels”.
ABOUT FIRST MILE
First Mile makes it easy for UK
businesses to recycle and improve
corporate sustainability.
One of the only accredited B
Corporations in the sector, First Mile
have grown rapidly over the last 10 years,
and now serve 30,000 UK locations,
delivering high recycling rates, and
low-impact collection models, including
EV’s and cargo-bike collections that
allow thousands of Central London
businesses to have waste collected with
zero emissions.
26 SKIP TO RESOURCES September 2024
www.uroc.uk
Profile
Retired not on your Nelly,
even if I wanted to!
UROC was delighted to catch up with trailblazer Jacqueline O’Donovan to find out what
she has been up to since successfully completing on the acquisition of O’Donovan Waste
Disposal Limited by Sortera.
Jacqueline O’Donovan
OBE was the
Managing Director
of O’Donovan Waste up
until its successful sale
in May 2023. Jacqueline
has continued to work
tirelessly to promote safer
and more sustainable
practices that can be easily
adopted and integrated into
working practices within
the industry. We caught
up with Jacqueline after a
UROC round table strategy
meeting, as she is on our working
group reviewing the ‘Resource
Framework for Aggregates from
Inert Waste’. We are pleased to say
that Jacqueline is still committed to
the industry.
Jenny Watts, CEO of UROC
said “Jacqueline has always been a
committed supporter of UROC and we
have always valued her high end input
into developing policy and fighting in
the waste operators corner”. As we
delve into what Jacqueline has been up
to since the sale, it is evident, she tells
us “although people think I am retired,
this industry is infectious you never
want to leave. I am passionate about our
industry and had the honour of being
bestowed with an OBE (Order of the
British Empire) in 2023 by King Charles
III for my services to recycling, safety
and industry. It was not only a shock but
an enormous privilege to have received
it and be recognised for the work I
have done”. This is, of course, a huge
accolade and definitely well deserved –
many congratulations Jacqueline!
Jacqueline O’Donovan OBE – Managing Director, O’Donovan Waste
As a very active hands-on Managing
Director Jacqueline went on to tell us
about how she is filling her time these
days. Jacqueline tells us that she is
happy to say that she has never been
busier in fact she does not know where
the days and months have gone. “I am
loving everything I am doing and the
biggest change for me is the variety of
sectors that I am moving into.” Using
the knowledge that she has gained in
selling her company she advises us that
she is now also helping other companies
navigate the process of selling their
business. She has also started a PR and
Marketing Company ‘ODPR’ which
specialises in the construction industry,
the supply chain and logistics.
Jacqueline continues to tell us that
being able to sit on UROC working
groups is extremely important for
her as she feels the industry can
unintentionally make unnecessary
complications and place burdens on not
only the operator but also the regulator,
she said, “Having the opportunity
to use my expertise with the aim of
ensuring that the new Resource
Framework for Aggregates is fit
for purpose and that companies
can operate to the standard is
very rewarding”.
Jacqueline is widely known in
the industry as a trailblazer and
campaigner for improvement in
addition to being part of UROC’s
working group engaging with
the Environment Agency she is
also the campaign director for
‘Change drivers hours regulations
for the better’. Jacqueline went
on to explain that “drivers
regulations are archaic and not fit for
purpose for local businesses. Increasing
safety, reducing the environmental
impact not to mention the driver
shortage will have a massive positive
effect on the industry resulting in
bringing down the average drivers
age from 56”. The campaign kicks off
in early September. Any companies
that wish to join or know more
about the campaign can visit www.
changdriverregulationsforthebetter.co.uk
to register their interest.
Jacqueline concluded with “I truly
believe that the camaraderie and
relationships that you build up in this
industry remain for a lifetime.”
It is paramount that people like
Jacqueline continue to work within the
industry, leaving a legacy of change
for the better. We are delighted to have
Jacqueline taking part at our Panel
Session on Secondary Aggregates in the
Materials Village at the RWM show on
the 12th September 2024.
www.uroc.uk September 2024 SKIP TO RESOURCES 27
Markets
Captain Pringles! Recyclability
Revolution
With Packaging Extended Producer Responsibility firmly in the statute book, it is now
incumbent upon those who place packaging into the marketplace to rethink the design and
life cycle of their products. Simon Ellin explores the Pringles journey…
Dr Simon Ellin
In 2016, as then CEO of the
Recycling Association, I had one
of my rants about the broken
recycling system with the BBC’s
Environment Correspondent, Roger
Harrabin and high on my rant
agenda that day was how so many
every day products are not designed
for recyclability. So, Roger suggested
I choose the top 5 hardest to recycle
everyday products for an article
on the BBC website. I duly obliged
and named the Pringles tube (or
can as owners Kellogg’s call it) as
#1 offender, due to the 5 materials
it is made from – cardboard sleeve,
metal base, metal-based liner, tear
off foil lid and a plastic cap. Indeed,
the construction involves so many
materials, that the Environment
Agency even view it as illegal to
export.
AWARENESS RAISING
The article was published in June 2016,
and it had a phenomenal impact. It was
a #1 hit worldwide on the BBC website,
trended top 5 on Twitter in the UK and
that day, as well as BBC Breakfast, I did
a further 25 TV and radio interviews.
It literally went viral, and the feedback
was astounding. It was the first time that
the British public (indeed the global
public with its reach) had looked at the
everyday products they buy in terms
of recyclability. It was the start of the
producer responsibility revolution and I
am proud that The Recycling Association
are the fore runners for the improvements
we are now seeing, and I am also
immensely proud to see that Kellogg’s
have announced the redesign of the ‘tube’
and is now rolling it out in the UK.
ADVICE
A great part of the story is that far from
me becoming an enemy off Kellogg’s
(well, after the initial hubris), they
sought my advice on how to improve
the product, and this culminating
with me visiting their Belgian factory
last year to look at the new protype
and offer my advice. It was a real eye
opener as to everything that goes in the
manufacturing process.
MANUFACTURING
So, what have Kellogg’s done? Well, the
main change is that they have replaced
the metal base with a cardboard one
– the base provides the rigidity of the
product allowing transportation and use
without damaging the product. It also
helps to keep the product airtight, giving
it a shelf life of 15 months. The structure
is now made from 100% recycled paper
and the inner liner, which is required
for food safety reasons, is easy to detach
in the recycling process. Interestingly,
for now, the plastic cap remains, and it
may surprise you to learn that I accept
this for now. The cap not only allows
the consumer to keep the product fresh
after opening, but it is also integral to the
factory process. Pringles are packed into
the tube in the factory from the base,
with the plastic lid already on and the lid
facilitates the friction on the conveyor belt
for the product to move at the correct
speed. Trials have taken place with a
cardboard lid, but the friction process on
the belt simply doesn’t work in synch with
the rest of the packing process. It is my
understanding that Kellogg’s are looking
to move to a carboard lid, but for now,
the plastic lid will remain.
IMPROVEMENTS
The redesign has cost in excess of $100
million and I applaud Kellogg’s for
reacting to the problem. The visit to
the Pringles factory was an eye opener
for me and I left there appreciating far
more what goes into the design of a
product. It is a very fine balance between
factory process, food safety/transit and
recyclability. The result is a Pringles
tube which is now 90% recyclable, and
I accept that massive improvement
for now, but look forward to Kellogg’s
removing the plastic lid going forward.
What a journey!
Contact Simon Ellin for business
consultancy support -
simon.ellin@ntlworld.com /
07531803986
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