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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

www.uroc.uk


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

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15 - 16 October 2024 | ExCeL London

ENABLING INVESTMENT INTO THE FUTURE

OF RECYCLING, REMANUFACTURING

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8 SKIP TO RESOURCES September 2024

www.uroc.uk


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

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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

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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

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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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