Environmental Regulation & Managing Waste Tyres
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The document discusses the complexities of managing waste tyres and outlines regulatory frameworks for their recycling and final use. It highlights the criteria for classifying processed tyres as 'end-of-waste' and details applications in civil engineering, sports, and consumer products. Additionally, it provides guidance on regulatory positions concerning permits and standards relevant to the use of tyre-derived materials.
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Environmental Regulation & Managing Waste Tyres
- 1. Environmental Regulation & Managing Waste TyresJohn Dyne
- 2. Are waste tyres ‘difficult’?QuantitiesFly tippingTyre ScamsArsonSpontaneous combustionLandfill banFinding outlets
- 3. Waste Framework Directive‘End-of-waste’ specifications and criteria should be developed for tyres‘End of waste test’‘when it has undergone a recovery, including recycling, operation..’(a) the substance or object is commonly used for specific purposes;(b) a market or demand exists for such a substance or object;(c) the substance or object fulfils the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products; and(d) the use of the substance or object will not lead to overall adverse environmental or human health impacts.
- 4. Draft WRAP Protocol ‘end of waste’ criteria for the production and use of tyre-derived rubber materialsTyre derived rubber material must require no further processing before use:EWC 16.01.03 end-of-life tyres only*
- 5. Processing in accordance with Quality Protocol*
- 6. Conformity with material standard (e.g. PAS107:2007)*
- 7. Conformity with one of the size categories stated in Quality Protocol*
- 8. Conformity with specified engineering standards (civil/ landfill engineering)
- 9. Conformity with any additional customer specification
- 10. Material must achieve certification from an approved body / records*
- 11. Material must be destined for use in a designated application*
- 12. QP compliant material can become waste again, if:Disposed of, or
- 13. Stored indefinitely with little prospect of being used, or
- 14. Mixed with waste materials.The Environment Agency’s position This position applies only to waste streams set out in Annex 1 where the waste has been processed and is being used in one of the final uses specified for that waste type in Annex 1. The producer must be able to demonstrate that the processed material is ‘suitable for use’ and can meet one of the relevant standards listed for that waste type in Annex 1. While the work of the Waste Protocols Project is in progress, our position is that these waste streams remain waste until the point of final use. However, it is possible for producers to show that the waste has been completely recovered on a case-by-case basis having regard to the aims of the Waste Framework Directive and the need to ensure that its effectiveness is not undermined. During the process of determining whether a Quality Protocol can be produced, we recognise it may not be appropriate to take enforcement action if an operator does not obtain an environmental permit for that final use of waste.
- 15. The regulation of materials being considered by the Waste Protocols Project Purpose of this position statement This position statement advises our staff and customers on how we intend to regulate wastes being considered by the Waste Protocols Project – a joint Environment Agency and WRAP (Waste & Resources Action Programme) initiative. The statement sets out our regulatory position for the interim period between when a material is accepted for inclusion in the Waste Protocols Project and a decision being made by the Environment Agency and European Commission under the Technical Standards and Regulations Directive 98/34/EC. The current waste streams and end uses being considered are listed in Annex 1.
- 16. 8. Tyre-derived rubber material Final use Processed for use in: • civil engineering (road applications): o as a replacement aggregate in the construction of roads including roadbed stabiliser, slope stabiliser, drainage fill and as an additive for rubberised asphalt; o as a loose or bound material in the surfacing of footpaths, nature trails, cycle paths, bridleways and roads. • civil engineering (non-road applications): o as a replacement aggregate in the construction of culverts, drainage channels and bridge abutments; o as a replacement aggregate in the construction and building industry, e.g. use in block fabrication; o as a bound rubberised product including wall and floor boarding (e.g. chairs and signposts) and railway crossing surface matting. • landfill engineering: as a replacement aggregate in the construction of landfill sites (e.g. as a drainage layer). • sports, recreation and leisure applications: o as unbound rubber granulate in sports surfacing (e.g. artificial turf, race courses, equestrian surfaces and running tracks); o as unbound rubber granulate in recreation and safety surfacing (playground surfaces, nature trails, bridleways, cycle trails); o as a bound rubber granulate and/ or powders in safety surface matting, anti-vibration matting, impact protection barriers and street furniture. • industrial and consumer applications: o automotive (e.g. new and remoulded tyres, mats and moulded parts); o street furniture and road surface matting (e.g. level crossings); o rubberised tiles and insulation mats; o rubber matting (e.g. livestock mats and mattresses); o as ingredients in rubberised adhesives and mastics; o manufacturing of consumer products (e.g. footwear and stationery); o carpet underlay. Relevant standards • BSI PAS 107 Specification for the manufacture and storage of size reduced tyre materials
- 17. We will adopt the following approach for wastes listed and used for one of the final uses specified for that waste type in Annex 1: • If you require a permit for the listed final use of the processed waste but you do not yet have one, we will not normally require you to have one provided:4 o the waste is not mixed with other wastes; o the waste is only mixed with non-wastes that improves its use or application; o the activity is carried out in such a way that it does not, or is unlikely to, cause nuisance or harm to human health or the environment.
- 18. Enforcement By not requiring you to obtain an environmental permit, we will not normally take enforcement for the lack of a permit unless the activity has caused, or is likely to cause, pollution or harm to health or a nuisance
- 19. Legal issuesThe tyre derived material must: be capable of a use specified in Annex 1be unlikely to, cause nuisance or harm to human health or the environmentnot be submitted to a disposal operationnot be mixed with other wastesAny pending proceedings would have to be stayed
- 20. ConclusionsTyres will remain an emotive subjectThe regulatory position statement is helpfulThe Wrap Quality Protocol and end of waste criteria is helpfulThere are a number of existing and emerging outlets for tyres
- 21. Potential outletsRemoulds and Retreads: the re-use of tyres for cars and light trucks.Tyre crumb used for carpet underlayTyre crumb used in micro-asphaltMicrobial DevulcanisationEquestrian Surface: Tyre chip for an all-weather gallopBaled tyre substitution of aggregate for landfill sitesTyre chips for lighter weight Construction BlocksShore protection using waste tyresTyre bales for use in embankment constructionConversion of used tyres and tyre shred into carbon black, oil and steel
- 22. Questions?