Important Call for Evidence – Waste Quality Protocols Review

The Environment Agency are in the process of reviewing the QPs for Compost, Anaerobic Digestate, and Poultry Litter Ash. At this point no decision has been made as to whether the Environment Agency (EA) will continue or withdraw its support for these QPs. ADBA would like your input so we can respond to the EA and ensure the industry’s position is considered.

If support is withdrawn OR it is deemed necessary to complete a revision of the QPs then further, more detailed, calls for evidence will take place at that time.

What: Quality Protocols (QPs) are end of waste frameworks that are used by Industry on a voluntary basis to identify the point at which waste, having been fully recovered, may be regarded as a non-waste product. This means the waste derived material can be used in specified markets without the need for waste regulation controls. The QPs are waste specific.

Follow the link for the Call for Evidence briefing note and a contact Sam Hinton for the spreadsheet template for responses. We would like your views on these 3 current QPs (Compost, Poultry Litter Ash and Anaerobic Digestion) as follows:

• Issues of clarity – Is the text of the QP clear?
• Any abuse of the QP that you are aware of – Please specify what the abuse is and if possible provide evidence.
• Are there any aspects of the QP that you find onerous to meet and why?
• Are there any aspects of the QPs that you find too lenient and why?
• As it stands, do you think that even if the QP is followed it nevertheless creates a risk to the environment and/or human health, if so why? Can you provide any evidence?
• Are there developing or new waste processing technologies that could be included in the QP?  These could be newly emerging technologies which have developed after the QP was published, or pre-existing technologies that were not included in the original QP design. Please provide evidence of their efficacy.
• In relation to the QP are there any uses and/or new end product markets that have developed since original publication which could be added now?
• In relation to the QP has there been any revision of or developments relating to the product standards set out in the QP relevant to the use(s)?  Have there been any new product standards published since original publication of the QP which you believe should be included?
• Are there any other relevant issues you wish to raise in relation to the QP?

Anaerobic Digestion specific QP questions previously raised by Environment Agency staff:

• Do you think there is a market for the digestate that meets the QP requirements and if so what is it?
• Do you think that QP compliant digestate has more potential to pollute than the comparator substance (i.e. pig slurry) and why? Do you think the QP compliant product is as stable in storage as that of the non-waste comparator? 

Please e-mail your comments, and or evidence, to Sam Hinton who will be compiling an industry response through ADBA.

The deadline for getting comments back to us is Friday 31st January 2020