An informal draft of a Directive requiring separate collection of hazardous wastes from households and other "municipal" sources such as small businesses were circulated by the European Commission earlier this year (ENDS Report 265, pp 41-42 ). The 18 waste categories include paints, aerosols, garden chemicals and solvents.
The proposals are linked to EC policies on pre-treating waste before landfilling and reducing the amount of biodegradable municipal waste sent to landfill (ENDS Report 265, pp 40-41 ). The Commission believes that removing hazardous wastes from the municipal waste stream will make it easier to recover the non-hazardous fraction.
The proposals would leave it to Member States to decide what form collections should take - bring schemes, kerbside collections or both - and how they should be funded. Making product suppliers pay for take-back or recovery schemes would be one way of avoiding an increase in local authority waste management costs.
Addressing a conference of the National Household Hazardous Waste Forum (NHHWF) in June, Kees Wielenga of the Commission's Environment Directorate, DGXI, said that extending producer responsibility to some of the wastes covered by the proposal would be "a very interesting idea" but would not be written into the Directive. "If it is very difficult to get agreement with producers on a national level," he said, "it would be even more difficult on an EC level."
Mr Wielenga said that DGXI is preparing a second draft of the proposals and it is likely that several of the wastes listed in the first draft, such as aerosols, septic tank sludge and bleaches, will be dropped.
Industry has argued that some of the other categories, such as paints, are too broad, as not all household products are hazardous. Mr Wielenga said that DGXI is still considering this issue, but noted: "It is hard enough to tell the public to dispose of their paint separately, let alone just certain types of paint."
DGXI is hampered by a lack of reliable data on costs. In the UK, one local authority puts the cost of the Directive as high as £500 per tonne. Another authority, with a population of 2.1 million and handling 800,000 tonnes of waste per year, estimates that its costs could range from £1.2-7.7 million, based on the assumption that 1% of total household waste is hazardous and is separated. It believes that as long as hazardous waste accounts for such a small proportion of the household waste stream, the best practicable environmental option is to leave it where it is.
The Local Government Association has suggested that the Government should introduce producer responsibility arrangements such as those established for packaging waste, with producers funding local authority collections and subsequent recovery or disposal. Such a system, it says, would provide a financial incentive for firms to reduce their use of hazardous materials.
The NHHWF, whose members include manufacturers and retailers as well as local authorities, has also called for the establishment of material-specific take-back systems or point-of-sale return schemes where appropriate for particular products, such as engine oil, nickel-cadmium batteries and fluorescent tubes - a waste category which it wants added to the list.
The Forum believes that costs will not increase significantly provided that civic amenity sites remain exempt from the "special waste" regulations and disposal of commercial wastes at such sites is limited to those covered by the Directive. But collection schemes will also be needed for especially hazardous wastes, such as acids or other chemicals, and the costs of operating such services in rural areas will be high.
Local authorities are also concerned that household hazardous waste should remain exempt from controls under the special waste regulations, otherwise there could be significant licensing costs at household waste recycling centres or retail premises operating as "bring" sites.
Gillian Verrall of the Department of the Environment's Waste Policy Division told the conference that some trade associations want their products excluded from the scope of the Directive.
One such sector is the paints industry. Wally Obo, Quality Assurance Manager for Akzo Nobel's decorative coatings business, told delegates: "A voluntary scheme is preferable to legislation which...is going to confuse and cost." But when asked by ENDS how many people in the UK live within easy access of a paint collection scheme, he acknowledged: "We've not got very far - a lot more is necessary."
Richard Knollys of the British Aerosols Manufacturers Association (BAMA) also questioned the need for the Directive. "In the interests - apparently - of harmonisation many items would be removed from the domestic waste stream which are already disposed of satisfactorily." The BAMA is keen to increase the UK recycling rate for aerosols from its present level of only 7%, but believes that separating them from the household waste stream and bulking them up "might create a risk."
The Environmental Services Association (ESA), which represents waste management companies, performed a difficult balancing act in its response to the proposals. On the one hand, it recognises that the Directive may result in "business generation benefits" for ESA members, because councils would need to invest in new collection and treatment services. But it is uneasy with the implied criticism of the current role of landfill in taking hazardous materials mixed with other household waste.
The ESA says that there is only "limited justification" for the proposal from the point of view of the impact of household hazardous waste in landfills. But it adds: "If this material was removed from the waste stream, it would perhaps make it easier to ensure that trace levels of persistent toxic compounds do not get into landfill leachate [and] make it more difficult to manage."
Meanwhile, the crossed-out wheeled bin symbol - already required on some batteries to indicate that they should not be disposed of with other household waste - has provoked universal dislike among businesses and local authorities because it does not tell the public how to handle the waste. The NHHWF recommends providing a helpline number for the public, as major retailers did as part of the Environment Agency's "Oil Care" campaign. If a marking system is necessary, it suggests that this should be based on the Chemical Hazard Information and Packaging (CHIP) system - but it acknowledges that this, with 15 categories and different messages, may be confusing for the public.