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DEFRA MRF Code of Practice Operator perspective Stuart Hayward-Higham

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Page 1: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

DEFRA MRF Code of Practice

Operator perspectiveStuart Hayward-Higham

Page 2: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

What is the aim of the CoP?

• A mandatory legislative scheme for the industry

• To meet the required provisions in the Waste FrameworkDirective (WFD)

• Supports the need to ensure products are fit for reprocessorsin the UK and the export markets

• Encourages good industry practice

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OCTOBER 2014

Page 3: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

What SITA is doing

Processing

1. Sampling and testing regimes at facilitiesin the UK generating product for the market

2. Create infrastructure and manpower tocarry out the sampling and testing regime

3. Processes to ensure feedstock materialand product are tested to the prescribedfrequencies and weights

4. Reporting procedures that will complywith the regulators expectation

5. Install signs at sites for feedstock,products and residual for definition

6. Standardised material acceptance processto use across the business

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Collection

1. Material quality training for all drivers

2. Liaise closely with customers to ensureDry Mixed Recyclate is fit for purpose

3. Create reports and procedures to inform

Local Authorities how they are performing

4. Processes and procedures for collectiondrivers and loaders to follow to ensure DryMixed Recycling is fit for collection

5. Visual prompts for drivers, loaders and

general public to encourage correct materialis in the appropriate container

Page 4: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

SITA considerations

> Current SITA Policy and Procedures are outlined , tested and theresults of the 2013 trial year are being learned.

> We will test more facilities than are ‘in scope’ to reflect our policy ofproducing quality products.

> Staff training, especially in obtaining a representative sample isessential. This will be the most difficult but most importantcomponent.

> Most likely opportunity to skew any results is ‘selective’ sampling,regulator inspections and mass balance checking is essential to ensurelevel playing field and consistent results between facilities.

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Page 5: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Customers impacts on CoP

• Quality comes from what is put in the bin.Contamination and/or out of scope Recyclate (materials that cannot be extracted at the MRFbecause they are outside the design specification)

• Contamination is the sum of the collection round, notjust a single bin inspection. Understanding crosscontamination and individual party contribution tototal contamination will become more important.

• Matching feedstock to facility and amending both in acoordinated manner

• Site visits will help show the net results

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Page 6: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

What is affected and how• “In scope” MRF Operators that process over 1000 tonnes of Mixed

Dry Recyclate annually

They will be audited by the EA against these new permitrequirements

• Local Government Authorities that collect commingled Mixed DryRecyclate that is processed by a MRF operator

Material they supply to these MRF’s will be tested and reportedto the regulator for public record

• Reprocessors that receive products created from MRF operator

They will have the confidence that products created from theseMRF’s will have been tested to recognised reprocessor and

industry specifications the results of which will be publishedby the EA

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Page 7: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

SITA facilities likely to be “in scope”

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South&East

Mitcham(MRF

Barking(MRF

Central

Kirklees(MRF

Darwen(MRF

Landor(Street(MRF

Brackmills(Lane(MRF

(

North

West(Sleekburn(MRF

Binn(Farm(MRF((SEPA)

(

(

(

South&West

Wareham(MRF

Bodmin(MRF

Avonmouth(MRF

Pool(MRF

Page 8: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

SITA sites that need to sample Even though these facilities are probably not “in scope” they produce

material that is sold into the markets that need to be sampled toensure SITA specifications are being met

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South&East

Brighton)Security)Shred

East)London)SecurityShred

Eastbourne

Si5ngbourne

Leatherhead

Hounslow

Morden

Slyfield

Charlton)Lane)MRF

South&West

Yate

St)Erth

Fareham

Launceston

Greendale)MRF

East)Devon)MRF

Central

Denaby

Wolverhampton

Birmingham

Blackpool

Bootham

Coventry

Granville

Halifax

Kendal)Fell

Land)Rover

Leicester

North)Lincs

Salt)Ayre

Warwick

Wrexham

New)CrosbyLandor)st)SRF

Belfast)MRFMalpass)SRF

North

Scla5e)MRF

Inverness

Campground

Alnwick

Berwick

Hexham

North)Tyneside)TS

Byker

Page 9: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

CoP sampling and composition Material quality and composition testing measuring

Feedstock composition testing Product quality and non-target composition sampling

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Page 10: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Testing requirements

These are the current weights andfrequencies in the draft code, they maychange slightly

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Page 11: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Sampling results

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Page 12: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Bad practice - selective sampling

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Page 13: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Sampling example 1

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Data analysis by weight

- 6.2% films

- 0.2% denseplastic

- 0% - PET, denseand others

Page 14: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Sampling example 2

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Data analysis by weight

- 3.2% films

- 10.9% denseplastic

- 0.5% - PET,

- 0% other plastics

Page 15: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

How do you calculate• How do you proportion the output of recycled product between

customers considering• Contamination levels of the incoming streams• The process losses• The impact of different contamination types and their impact on process

losses• Levels of confidence

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Page 16: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

How do you calculate ??

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Customer A1000 t

Customer B1000 t

Customer C2000 t

5% 8% 3%ApportionedProcess losses

Tonnes productinto the MRF

Customer A600 t

Customer B400 t

Customer C1800 t

Customer A570 t

Customer B368 t

Customer C1746 t

Tonnes of productproduced

40% 60% 10%Contamination %

14% 9% 44%Apportionedproduct as %total input

25% 25% 50%

Page 17: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Reporting

When Reports will need submitting to the regulator every 3 monthsWhatFeedstock: The total weight of feedstock received at the MRF from each named supplier The total number of samples taken The total weight of all the samples The average percentage composition of glass, metal, paper and plastic The standard deviation of the average percentage composition levels for the target materialsProducts: The total weight of the products produced by the MRF The total number of samples taken The total weight of all samples The average percentage composition levels of all the samples by reference to the grades of glass, metal,

paper and plastic identified within those samples The average percentage composition levels of target, non-target and non-recyclable materials The standard deviation of the average percentage composition levels for the target materials

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Page 18: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Regulator inspections

• Serious what happens if…..

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Stage one Stage two Stage three

Page 19: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Review of results

• 3244 samples taken in 2013

• 97.7% pass rate for effective tests in 2013

• All facilities that carried out sampling reported a 100% quality record exceptAvonmouth that was in commissioning

• None of the facilities managed to complete all the required tests expected

• Some facilities over sampled certain materials and under sampled others sothey did plenty of sampling but failed to follow the guidelines set out in thesampling workbook

• Across all the depots a total of 947 tests were in excess of the minimumrequired

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Page 20: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Health and safety

> For sample collection we are putting people as risk, we must haveappropriate controls and safe procedures

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Page 21: DEFRA MRF Code of Practice - MRF Regulationsmrfregulations.com/PDFs/Stuart HH presentation.pdf · in the UK generating product for the market 2. ... (materials that cannot be extracted

Thank you

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Stuart Hayward-HighamTechnical Development DirectorSITA [email protected]+44 (0) 7970 233747