Inspectorate exposes shortcomings of waste management in Scotland

Waste management standards in Scotland have improved over the past two years, according to a report by the Scottish Hazardous Waste Inspectorate (SHWI).1 But it is also plain that many local authorities are not discharging their planning, licensing and enforcement functions adequately - and that operating standards and leachate and gas controls measure up poorly against official guidance.

The SHWI's report is its second, and covers the two years to the end of 1992. Many of its main findings are expressed in language remarkably similar to that of the first report - and it again lacks the essential quantitative information needed to evaluate the real state of waste management in Scotland and how it has changed over the past two years.

In 1991, the SHWI reported a "continuing improvement" in waste management standards. The latest report notes that standards are "continuing to improve". The 1991 report said there were "few examples of serious problems"; its successor says that "no serious pollution problems have come to light".

Despite the reassuring tone of these conclusions, the report nevertheless shows that there remain serious defects in Scottish waste management - in part bearing out the SHWI's warning two years ago that local authorities lacked the resources to discharge their existing functions, let alone those then about to be newly imposed by the Environmental Protection Act 1990.

  • "Many" local authorities are continuing to complain that they lack resources - and the SHWI has accepted that "there is some basis for these concerns."

  • Basic aspects of many authorities' work are not being done. "Some" have yet to separate their waste disposal and regulatory functions, despite being ordered to do so in June 1991. Draft recycling plans had been submitted by only 23 of the 56 authorities by the end of 1992, when the deadline set by the Government was 1 August - and even now only 39 have been sent in (see p 29 ). And only one authority has revised its waste disposal plan since the first plans were drawn up under the Control of Pollution Act 1974.

  • As in 1991, "many" waste disposal licences and resolutions have never been reviewed - some issued as long ago as the late 1970s - and do not reflect current operational standards. In addition, "some" contain conditions "which leave room for interpretation or are inadequate; most commonly, they are those relating to the descriptions of waste to be disposed, record keeping, and monitoring for both water pollution and gas." And as in 1991, the "fundamental condition which is sometimes omitted or frequently not enforced rigorously enough is the requirement to have full and up-to-date working plans."

  • "Some" authorities keep good records of site inspections, the report says. But "others keep few formal records". The report urges authorities "to strive to the achieve the frequencies of site inspection necessary to give effective and consistent control" - suggesting that some are currently falling short.

  • A total of 743 landfill sites have been identified as having the potential to generate gas. Of these, 468 have development within 250 metres. Appropriate monitoring regimes have been introduced at "many" sites, the report says, and no "serious" gas incidents have been reported.

  • On leachate, the report says that treatment measures are in operation at 70 sites, while leachate monitoring was being carried out at 113 landfills in 1991. This compares with a total of 350 operational landfills in Scotland. Leachate was being monitored at 26% of operational private sector landfills in 1991, compared with 48% of public sector sites.

  • Landfill standards generally "vary considerably between sites and throughout the country," the report says, being poorer at "some" older sites. The SHWI says it was "disappointed by the attitude of some operators, both public and private, who are content to operate their sites to minimal standards and leave it to the waste regulatory authorities to keep them in check." Random tipping, inadequate cover, litter control and record keeping, and lack of a phased restoration policy are the "most common grounds for adverse comment" - much, indeed, as they were in 1991.

  • On "special waste", the report observes that "deliberate abuse" of the consignment procedure is not "widespread". "Most" consignments are properly documented.

  • Again as in 1991, formal enforcement action outside the central belt of Scotland has been very rare. In 1991, 12 cases were reported to Procurators Fiscal for prosecution.

    Dissatisfaction with Fiscals' performance in pursuing legal action and the small fines imposed on polluters is commonplace among Scotland's river purification boards (ENDS Report 203, pp 27-28). A "number" of waste regulation authorities feel likewise and told the SHWI that enforcement could be eased if a Fiscal specialising in environmental cases was appointed. And "some" suggested that fines were "in many instances, too light to be of any deterrent value".

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