CIWM-September-2016-Special-Focus

CIWM Special Focus
Materials Handling & Recycling
Are our materials streams on target? – p42 • ELAs… that's end of life aircraft– p48
The Milton Keynes Waste Recovery Park – p52 • Have the MF Regulations helped? – p54
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In recent times, the waste management industry has been led by ever-changing
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Material recycling facilities are big investments and require trusted partners to support the investment and
innovation to meet today’s increasing demands on recycling waste. Allied Irish Bank (GB) works as a trusted
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kit, its design and performance, as well as the benefits the equipment solution will bring to the customer.
The processing of waste has become more of a manufacturing process today and therefore require partners to
help implement the desired solution efficiently. With the UK Government’s drive towards the 2020 EU recycling
targets, it’s a near certainty the goalpost will change again, as we continue to move ever closer to zero waste to
landfill, so investing with the right supplier and finance partner has never been more essential.
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CIWM | Journal September 2016
Paper
Simon Weston, director of raw materials at
the Confederation of Paper Industries…
BY THE close of 2015, UK domestic
collection of paper for recycling (PfR)
totalled 7.98m tonnes, only marginally
less than the 8.1m tonnes recovered in 2014. Progress to date
this year suggests collections are in line to exceed both previous
years. Sadly, off-take by UK mills fell in 2015 by close to 10
percent year-on-year, which was the result of the closure of 13
UK-based paper machines. However, export markets
stepped in to move the additional material. Last
year, for the first time, Chinese paper mills
used more UK-derived fibre than
domestic mills, demonstrating the
UK’s dependency on export
markets and the absolute
need for high-quality
output from the
system to meet
the needs of
foreign mills
and sustain
the recovery
infrastructure.
The second
half of 2015 did
not play out the way
some commentators
had predicted. There
was no collapse in market prices
after the closure of Aylesford Newsprint, nor
was it necessary to stockpile material.
Market prices remained depressed, but
stable, to year-end and have ticked up
steadily since the start of 2016. The Brexit
vote and consequent devaluation of the
pound, combined with seasonal shortages,
have created a sharp uptick in the prices of all
grades of PfR heading into mid-summer.
The paper industry has long been proud
of its recycling performance. The CPI has
calculated the national recycling rate for all
paper and board to have been circa 68 percent
in 2015, with the recycling rate for all paper-based
packaging being 81 percent.
However, the recent publication of the
Packflow study by Valpak (on behalf of
Defra) has estimated the amount of paper and board packaging
on the market (POM). The report estimated the amount of POM
in 2014 was 4.749m tonnes, an increase of 862,000 tonnes on the
previously estimated figure. Using the revised POM figure, this
means the UK achieved a 73 percent recycling rate for paper and
card packaging in 2014, rather than the previous Defra estimate
of 89 percent.
Regardless of the apparent uncertainty over recycling rates,
the European Commission (EC) target for paper is 60 percent,
whilst the national target until 2017 is 69.5 percent, so the
industry is still comfortably ahead of where it needs to be. In
addition, the Environment Agency is currently
deliberating about the packaging content
in mixed paper. Should it accept the
findings of a recently completed
industry sampling exercise
and increase protocol 023
above 12.5 percent, the
recycling rate will need
to be adjusted further
upwards.
No matter
the nature of
the post-Brexit
divorce, the future
of UK recycling policy
is likely to be shaped
by the EC Circular
Economy Package.
Of most interest to
the paper industry
are proposals to reform
the Extended Producer
Responsibility system.
If, as proposed, the supply
chain is required to take
full cost responsibility
for recovery of paper,
it is highly likely that
systematic changes to
recovery systems will be
demanded. This could
lead to upheaval in
current contracts
and structures with
significant costs
falling to current actors
as existing systems are
reorganised.
18 Months On...18 months ago we asked organisations representing a range of materials streams to tell
us about targets and challenges in their own particular sector. But what's changed in a
year-and-a-half? Well, Brexit for one thing! Our experts return with an update…
MATERIALS HANDLING & RECYCLING
Materials Handling & Recycling – CIWM September 201642

September 2016 CIWM | Journal
Wood
Andy Hill, chairman of the Wood
Recyclers Association (WRA)…
Since my last update in April 2015, I’m
pleased to report that the wood waste
recycling industry has remained robust, continuing to make a
significant contribution to the reprocessing of some 4.5m tonnes
of wood waste arisings produced annually in the UK. This makes
our industry one of the most important in helping the UK to
achieve good recycling rates and landfill avoidance levels.
Looking back over the past 18 months, there have been two
major developments in our sector. Firstly, the development of
UK biomass plants, much vaunted over the past 10 years, is
finally coming to fruition with the start-up of a number of new
facilities and still more to come.
The WRA estimates by the end of 2017 this will provide in
excess of 1m tonnes of "new" domestic demand for recycled
wood-based fuels. This in turn will put pressure on exports from
the UK to Scandinavia and northern Europe. Accordingly, we
expect to see the export market react by firstly improving pricing;
and secondly to start sourcing from other parts of Europe to
replace UK volume (in fact, we’re already seeing evidence of this).
Additionally, in my previous update, I touched on the difficult
and uncertain regulatory environment the industry was facing
(and I refer to the wider waste management industry, not just
wood) relating to the introduction by the Environment Agency
(EA) of its Fire Prevention Plan guidance (FPP).
The last 18 months have been very turbulent as a result
and, despite repeated attempts by the WRA and other forums
such as WISH, the EA has failed to properly and fully engage
with the industry or the Fire Service. Its dogmatic insistence
of pushing ahead with a "one size fits all" piece of regulation,
based on very little science, at best defies common sense and
at worst is an example of "bureaucracy gone mad".
Sadly, there is a real risk that many reputable and high
quality operators will go out of business as a result. At a time
when central government has issued a clear instruction to civil
servants to cut red tape in an attempt to not hinder business,
this exercise has consumed thousands of hours of time
and cost significant sums; yet we are still no further forward
than we were four years ago.
Once again, I would reiterate to the EA that the WRA is
fully committed to working with it to produce an appropriate
piece of regulation that is fit for purpose and satisfies as many
stakeholders as possible.
Looking ahead, the WRA is making plans to introduce quality
criteria for membership in order to further raise the standards in
our industry, building on the good work that’s already been done.
Will Brexit make a difference? I think it’s too early to say,
but my personal view is that despite the sometimes absurd
dictats from the EU, it also made a positive and significant
contribution to getting the UK recycling and landfill diversion
rates to where they are today. I personally find it hard to
believe that either the Government, or indeed public opinion,
will allow the UK to go backwards, but the key question for our
whole industry remains as to how the Government will move
forward. Will it continue to push recycling rates? Will it invest
in infrastructure? If someone out there has the answer, please
let me know! What is clear though, is that we are (and will be
for some time) part of a European market.
Lamps
Nigel Harvey, chief executive of Recolight, a
specialist UK WEEE compliance scheme
for the lighting industry
SINCE 2014, the Government has set
national WEEE collection targets to be funded by producers via
their compliance schemes. In 2016, the lamps target was set at
6,882 tonnes – a significant increase from 2,680 tonnes in 2015.
This increase reflects the fact that most waste lamps collected
from businesses can be used to meet the national targets. The
Government chose 6,882 tonnes as the 2016 target based on its
forecast of the tonnage of waste lamps that is actually likely to
arise in 2016. Their objective is broadly to balance the supply of
waste lamps with demand for those lamps from schemes.
The higher target has important benefits for waste
management companies: WEEE schemes in the UK will need to
collect 6,882 tonnes-worth of recycling evidence notes, which
represents virtually all waste lamps collected in the UK. So any
waste management company that is collecting and aggregating
waste lamps from businesses should be able to access free
of charge lamp recycling. That is because the lamp recycler
they are using may well also be getting revenue by selling the
associated evidence notes to a WEEE scheme.
At Recolight, we think the Government adopted the right
approach when it set the 2016 lamp target. As the UK’s largest
WEEE lighting compliance scheme, Recolight has responded
by offering free collection and recycling of waste lamps to any
business that collects more than 1,000 waste lamps per quarter.
At the time of writing, only the Q1 2016 WEEE collection
data had been published, and so commenting on the likelihood
of the UK meeting the target is a little premature.
But the Q1 data would appear to be on track.
Plastics
Stuart Foster, CEO of RECOUP, is
adamant that the opportunity exists
to take plastics recycling to the next
level, but not without a refresh of
policy and business direction…
FROM UNCERTAIN post-Brexit impacts on markets
and legislation, company acquisitions and reprocessor
administrations, to intensifying packaging scrutiny, wider
collection system reviews, and continued lack of investment in
consumer education – plastics recycling is in transition.
In 2015, the UK exceeded plastic packaging recycling targets
with a reported 891kt recycled. More than half of this came from
household-sourced packaging including bottles, pots, tubs and
trays, with the remainder being mostly films from commercial
and industrial sources. By extending the targets set from 2017
to 2020, Defra recognised the need for additional time to install
and improve the necessary infrastructure alongside changing
recycling behaviours. But that now needs to happen.
Creating the right balance of legislative drivers and
positive long-term business conditions should allow for a
viable and resilient system to be established to meet future
increased plastic recycling targets and maximise best use of
plastic resources. The EU provided a policy landscape in this
sector that was relatively stable and effective for business
and environmental development, with game-changing ➥
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directives on the horizon. If a Circular Economy Package,
together with more recycling, is a good idea, we now look
to the UK and devolved governments to make sure a robust
strategy is not just implemented but also financially backed.
There is also a real need to ensure plastic circular economy
thinking goes beyond recycling.
Markets need to be supported and stimulated. Green
procurement initiatives need to ensure much wider use
of recycled plastics in the manufacturing of new products.
This will also involve a mandate for recycling systems
to provide the ongoing quantity and quality of plastics
needed to meet manufacturing sector requirements,
within sensible and justifiable business arrangements.
Work on recycling more plastics from other sectors
including bulky household plastic products, waste
electrical and electronic equipment and end of life vehicles
is also important and represents good opportunities.
The potential for more recycling and better use of
resources is undeniable, and RECOUP and its network are
determined to work together to take plastic recycling to
greater heights. There is a real opportunity to review and
bolster the foundations that will allow plastic resource
efficiency and recycling to grow and prosper into the next
decade or more, but I expect this will be realised or lost by
decisions and actions that are taken in the next year.
This and more topics will be covered in our annual Plastics
Recycling Conference on 29 September, where we continue
to bring together the whole of the plastics supply, use and
recycling chain to discuss and debate the issues important to
the industry and all its sectors.
Textiles
Alan Wheeler, director of the Textile
Recycling Association…
SINCE WE last visited the issue of
whether textiles are making an effective
contribution to recycling targets or not, there has been some
headway, but there have also been some setbacks. After the
referendum it seems a little bit pointless to concern ourselves
with the EU Circular Economy Package… that said, at the time it
came out I was disappointed that a more specific steer towards
targets other than those based on weights was not given.
As you probably know, the actual physical amount of
textiles in the waste stream is relatively low compared to most
other material, so if it is just weights that will drive the circular
economy, then quite frankly very few are going to bother with
textiles! However, as our knowledge of resource management
has improved, we now understand that recycling one tonne of
material can have a significantly different impact to recycling
a tonne of different material. When it comes to recycling or
reusing textiles, this actually results in very significant carbon,
water and waste benefits. In fact, textiles leave most other
materials behind…
So you can perhaps see why I would have hoped for a more
definite move towards targets based on carbon benefits or
other environmental indices. However, what is perhaps more
worrying is that if we leave the EU our need to collect and
reprocess more materials will effectively disappear. It is true
that unless the law is repealed we will still be required to reach
our national recycling targets by 2020, but if we do not meet
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them what effective action can be taken?
Inside the EU, any country that fails to meet its international
responsibilities by ensuring that they reach their targets
could be sanctioned by the other countries and fines imposed.
Serious environmental issues can only be addressed through
meaningful international co-operation, so this system of the EU
being able to impose fines on countries that do not meet their
responsibilities is rational. However, if as it seems may happen,
the UK fails to meet its obligation to reach its recycling targets,
what will happen now? Surely the EU would not be able to
impose sanctions on us when outside the EU?
Andrea Leadsom MP, as Defra's Secretary of State, may now
appreciate the crucial role that the EU has played in shaping
the UK’s environmental protection and policy measures and
how it has led us from being the "dirty man of Europe" that we
were in the 1970s, to the respectable performer that we are
today. It is vital that she ensures that the progress our sector
has achieved under its membership of the EU is protected and
that the UK’s responsibilities to its own people and the global
community are maintained.
So where has the headway been made that I referred to?
Well we still have the issue that the majority of textiles collected
never become waste, are never captured in waste data flow
figures and hence are not being captured in the official national
reuse and recycling rate figures. In total, about 600,000 tonnes
of materials that are mainly being reused is being missed out on.
Whilst we have not yet found the complete solution,
discussions have been ongoing with Defra and it seems that
we may be able to capture up to one-third of this missing
tonnage through a relatively simple change in the way the data
is captured. If between now and 2020 we can work out how to
capture the remaining missing tonnes, then textiles could make
a significant contribution towards making up the shortfall in
meeting the 2020 targets. But if we don’t meet the 2020 targets,
who is going to do anything about it?
Glass
Dave Dalton, chief executive of British
Glass – the trade association for the UK
glass industry…
DESPITE WEAKNESSES in glass
recycling infrastructure, I am confident
that the recent government reformulation of DECC and BIS
responsibilities, and the UK’s EU exit negotiations, open a
window of opportunity to achieve more and better quality
glass for recycling.
The average recovery rate of post-consumer glass in the EU28
countries has reached an all-time high of 73 percent, according to
the most recent figures available. Here in the UK, the March 2016
budget statement announced Defra's glass recycling targets to
2020 – unveiling a one percent increase year-on-year.
This is, in fact, an ambitious target for the glass container
sector. In recent years, a fairly steady 600,000 tonnes of post-
consumer cullet has gone back into container production
annually. But set against an annual container glass waste
stream of some 2.4m tonnes, it is clear that there is more glass
out there. And the fact is that manufacturers want to use it –
but they can’t currently access it.
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the resulting government restructure can, and must, be seized
by the glass sector as an opportunity to secure its future.
With the details of the UK’s exit from the EU far from clear,
it’s hard to know what the EU Circular Economy Package will
mean for the UK. Given that trading with our nearest neighbours
will remain a priority, it seems almost inevitable that UK policy
on recycling and circular economy will continue to at least
broadly align with EU targets. Certainly in the short-term a
weaker GB pound gives the UK glass sector some advantages.
Perhaps most significantly, the creation of the Department for
Business, Energy and Industrial Strategy indicates, I believe, a
new way of thinking that positions energy (and so environmental
sustainability) as a mainstream component of industrial strategy.
A single point of access to government – with a shared goal of
better environmental performance and better productivity – is
something the glass industry desperately needs.
The UK glass industry has been proactively engaging
across government departments to reduce our environmental
impact for many years. Being able to increase the recycled
content of UK-manufactured glass packaging is something we
have highlighted throughout, because using cullet reduces
production costs, saves energy and drives down CO2 emissions
by over 600kg per tonne of glass produced. The commercial and
environmental incentives are there, and are clearly aligned.
But historically, coordinating the policy and actions of BIS,
DECC and Defra has not been simple – and the frustrating
and damaging result is that we still do not have a recycling
infrastructure that provides sufficient quantities of cullet at an
appropriate quality.
All of this, together, is why I think we have an unprecedented
window of opportunity to shape the vernacular of government
away from punitive taxes on so-called waste and towards
harnessing secondary resources to link economic growth and
environmental improvement. The chance to create a growing
and competitive manufacturing base that delivers sustainable
profitability and long-term tax revenues.
Right now British Glass is focused on facilitating
collaboration across the supply chain – working with local
authority recycling departments around the country and
bringing together brands, retailers and manufacturers in round
table meetings to define practical steps and interventions. And,
of course, we will continue to share honest, evidence-based
information between our members and government…
Construction & Demolition (C&D)
Peter Kelly, sustainability manager at
ISG and representing the industry’s
Construction and Demolition Waste
Forum…
THE INDUSTRY focus has stalled
somewhat, as a result of the merger between the UK
Contractors Group (UKCG) and the National Specialist
Contractors Council to form BuildUK, and with WRAP no longer
supporting the built environment.
THE UK Contractors Group, in conjunction with the Green
Construction Board’s Greening the Industry Group, have been
setting targets to reduce construction waste sent to landfill and
the amount generated since 2009. With the formation of BuildUK
in September 2015, an environmental leadership group exists
that has been working through the previous commitments made
by the UKCG to assess their relevance to BuildUK.
One of the first commitments tackled has been the reporting
of sustainability metrics, with waste still a key focus. Despite a
pause in data collection, as a result of the WRAP MeasuRE tool
no longer being supported, this portal may well be resurrected
by an alternative body, or a simple reporting mechanism will be
provided by BuildUK. This will not only continue performance
measurement, but also look to capture the data from the last
12-18 months.
The targets under the UKCG were:
• to divert at least 90 percent of C&D waste away from landfill,
with the aspiration of achieving zero non-hazardous C&D
waste to landfill by 2020
• to halve construction waste production by 2020 (based on a
2010 baseline).
Once an agreed format of reporting is established, these
targets will be reviewed and either adopted under BuildUK or
adapted to suit.
What is clear is that 2020 is not that far away; the future will
revolve around ensuring the following focus areas are embraced
by the industry:
• adoption of PAS 402 Waste Resource Management –
Specification for Performance Reporting by the waste
management industry
• working with the Building Research Establishment to finally
publish guidance on implementing pre-redevelopment
materials audits
• potentially working with CIRIA to look to reinvigorate
resource management planning, particularly with clients and
design teams
• ensuring that, as a result of Brexit, we do not lose the vast
opportunities surrounding the circular economy
• embracing new technology and systems, such as
deconstruction and recovery information modelling, which
aims to enable the identification of reusable and recoverable
materials at a building’s end-of-life.
There is still a lot of work to do before the industry
significantly reduces the amount of waste produced. However,
with BuildUK providing a vehicle for the supply chain and main
contractors to work together, I am confident that not just waste,
but the wider remit of sustainability, will come to the fore for the
construction industry as 2020 looms.

Metals
Robert Fell, British Metals Recycling
Association’s new chief executive…
IN THE 18 months since my predecessor
Ian Hetherington delivered his view on
the market for metals, end of life vehicles (ELV) and WEEE
in this publication, business has continued to be challenging
for most of the sector. Record low prices and continuing
shortages of metal scrap, combined with a noticeable lack of
enforcement has created an uncertain marketplace and an
uneven playing field.
The shortage, and in some cases disappearance, of
materials is of real concern. When it comes to ELVs, for
example, a significant number have seemingly vanished from
the system. While we believe many of these are being driven
out of the country or harvested for parts, which are then also
shipped overseas, there are currently no substantiated data to
support this.
Alongside the shortage of materials, further hurdles the
sector has faced and continues to face come in the form of
standards and regulations that make almost crippling demands
on businesses. From the Industrial Emissions Directive (IED) to
the newly released Fire Prevention Plan guidance, we are now
navigating very turbulent waters.
Under the IED, companies with metal fragmentisers – or
shredders – had to apply for a new permit that sees them
bound to a plethora of conditions. While the review of the
Waste Treatment BREF is ongoing, the Environment Agency
(EA) is setting its own interim conditions, some of which
may exceed those set out in the draft BREF. There is a real
concern that the cumulative effect of these requirements and
their associated costs could have significant impact across the
sector. In a time when metal prices are in the doldrums, many
companies are having to consider making costly adaptations
to their installations before it is known whether they will be
required by the BREF.
Furthermore, despite the cost involved, many companies
have applied for a permit only to be left waiting for many
months to receive them. In fact, of the metal recycling sites
that have shredders and who have applied for an IED permit,
as of 20 July 2016, five have had permits issued, 19 are in
determination and 10 have yet to be allocated.
More recently, the Fire Prevention Plan guidance has clearly
created waves across many sectors, not least scrap metal. It
was somewhat disconcerting that the Guidance was published
before the results of the fire tests being run by the Waste
Industry Safety and Health (WISH) forum. Hopefully, the EA
will stand by its suggestions that the Guidance could be revised
off the back of these results. As it stands, space constraints will
mean that meeting demands, such as separation distances and
pile heights, will prove impossible – especially for smaller yards.
Looking to a Brexit-based future, however, there is a
semblance of a silver lining to the clouds. One large gain would
be changing the designation of scrap metal. Currently, the EU
classifies scrap metal as waste and requires exporters to abide
by complex shipping regulations. In countries such as Egypt,
which have strict rules about importing waste, it is harder for
the UK to compete against countries like the US which label
scrap metal more favourably. Moving away from classifying
scrap metal as waste would be a very big win indeed.
Tyres
Peter Taylor OBE, Secretary General of the
Tyre Recycling Association…
A LONG-STANDING complaint of tyre
recyclers has been the damage done
to our marketplace by those at the fringes of our business
who can operate illegally… we have not always been served
well by those to whom we look for effective enforcement,
but times are changing and not necessarily for the better,
for we are starting to hear our regulators more than our un-
regulated competitors.
The on-going furore over fires at waste sites is a clear
case in point. After years of inconclusive discussion with
the Environment Agency, the concerns and arguments put
forward by the mainstream tyre recyclers have been totally
set aside in favour of a "one size fits all" framework that will
not work. The consequences are all too easy to predict, as
site capacities will be reduced by up to 50 percent and the
economics of their operation totally compromised.
This means that operators will be forced out of business,
jobs lost and responsible tyre recycling decimated. Like many
waste streams, ours is not highly profitable and the resources
needed to decamp elsewhere are simply not available. The
illogicality of it is dispiriting and for once we cannot blame the
rest of the EU for these pressures.
Yes, we do as businesses want to do all we can to reduce
risk but fires can start as a result of a number of factors not
least of which is arson; reducing stack heights to tiny piles is
not the answer but that’s where the emphasis is, not on site
security and early detection. Most galling of all is that our
industry’s real problems – sham recycling, a developing over-
reliance on the export of waste (both legal and illegal), coupled
with a poor history of effective enforcement, are issues that
the EA in particular find hard to confront.
What we desperately need is a level playing field in England
and Wales; those who operate below the radar need to be
exposed and put out of business. As a recent analysis graphically
demonstrated, the operating costs of a responsible operator are
almost three times those of say a covert baler operating from an
exempt site! This is an unconscionable state of affairs.
We badly need a new business-facing approach so can I
plead for more constructive and less destructive engagement?
I and many others would be delighted to assist, if only we could
escape the sterility of an approach which favours "form" over
real substance. Industry deserves it and those who ordain over
us owe it to themselves I believe. Life outside the box is not
threatening, but empowering. This may even be just the right
moment,: Defra has a newly-appointed Secretary of State, the EA
a recently appointed new chief executive and we must face up to
a post-Brexit world where things will need to be done differently.
For those of us at the sharp end I can only say that it would
be a real joy to feel that we were contributing to the success of
our industries and not endlessly attempting to argue the latest
ill-thought through and damaging initiative. <
"We badly need a new business-facing
approach so can I plead for more constructive
and less destructive engagement?"
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Plane
& Simple
Ever wondered what happens when an aircraft
reaches the end of its working life? Well,
it's a complicated process to recover
all of the reusable components
and materials, as
Aine Spoors explains
A
s you fly home from holidays, or from a business
trip, have you ever wondered what happens to the
aircraft when it reaches the end of its useful life?
According to the Aircraft Fleet Recycling
Association (AFRA) an estimated 12,000 aircraft are due
to be retired in the next two decades. As environmental
regulation becomes more robust, landfill regulations bite,
and the materials used in aircraft manufacture change, the
aerospace industry is constantly evolving, seeking new
environmentally-sound methods for aircraft disposal.
Previously, aircraft were retired on average at 30-plus
years old. Over the past 10 years this has changed due to
the improvement in technology, making newer aircraft
more efficient – the average age of aircraft being retired is
now 20 years and the time scale is reducing; some of the
newest aircraft GJD Services Ltd have disposed of were only
eight years old.
A newer generation aircraft can be worth more as
spare parts than as a whole, and many parts such as the
engines, avionics and landing gears are being re-certified
or overhauled and resold into the market place for reuse on
other aircraft, or being returned to the airline to be put in to
stock for use on the remaining fleet.
Aircraft require regular maintenance and important parts
need to be replaced before they fail. Aircraft contain life-
limited parts (LLP), which need to be replaced in accordance
with certain cycles, revolutions or timescales. When these
parts reach the limit of their useful life, they are sent for
overhaul and re-work, or sent for disposal by mutilation to
prevent re-entry in to the second-hand parts market. This
is vital to ensure that any removed parts that are not fully
serviceable cannot re-enter the supply chain; failure to follow
this procedure will compromise the safety of an aircraft.
As a result of European legislation, most notably the EU
Waste Framework Directive 2008/98/EC, aircraft had to
comply with the end of life vehicle (ELV) legislation. GJD
Articles with this stamp will
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became the first aircraft recycling company in the UK to
gain an approved permit for the dismantling and disposal of
aircraft under the Directive; it was a challenging process as
the classification of when an aircraft becomes "waste" had to
be clearly defined; working practices employed in the vehicle
disposal industry did not fit with the aircraft disposal industry.
The Depollution Process
IN ADDITION to the myriad of recoverable spare parts, an
end of life aircraft will have many pollutants classified as
hazardous waste, and the legislation requires that aircraft are
depolluted to remove these hazardous materials and fluids.
"Parting out" is the activity of removing salvageable
parts for reuse and is carried out by trained mechanics,
using the approved tooling in accordance with the approved
maintenance data. It is classified as a maintenance activity
to ensure these parts are properly handled and remain
airworthy. Cutting lumps off the aircraft to get access, or
cutting hydraulic lines to make the removal of a part easier,
are absolutely forbidden. The simple rule with parts removal
is that from the time the aircraft can no longer be put back
together to fly, then that aircraft becomes waste, and any
parts subsequently removed cannot be re-certified without a
"repair shop" visit.
The depolluting process is also laid down in the aircraft
maintenance manual and the aircraft disposal activity is
governed by a set of procedures approved under our bespoke
Environment Agency permit. The disposal activity must
be carried out on an area with impermeable surface and
sealed drainage system. When carried out correctly, after
depollution, a Boeing 747 will have no more than 10 litres of
residual oils trapped in hydraulic and fuel lines, which is an
insignificant amount considering there are over two miles of
pipes, tubes and wiring in each B747.
After the aircraft lands, its data plate (a unique plate
put on each aircraft when the aircraft is built) and the
registration number on the outside of the aircraft are cross-
referenced with the documentation on board the aircraft.
This process is part of the "back to birth" records inspection
for each component requiring re-certification or mutilation.
The first action after landing is to check for any
unserviceability that may affect any of the components
to be recovered; function checks are carried out of all the
systems… including flushing the toilets. Engine runs are
carried out at full power to check the take-off performance
data against a set of tables in the aircraft maintenance
manual. Once all of the aircraft systems are checked, the
aircraft is made safe by fitting safety pins and disabling
certain systems.
The aircraft is configured for parts removal, which will
include the lowering of the flaps, deploying the speed brakes,
dropping the undercarriage doors and fitting all required
locks to prevent inadvertent movement of flight controls or
undercarriage doors, which would easily cause serious injury.
Next the aircraft is depolluted, the fuel and hydraulic
systems are drained and the engineers remove all the
required components. Once the parting out element is
complete, the aircraft is certified to have had all required
items removed; at this time the airworthiness certificate is
revoked and the aircraft is de-registered. This is the point
where the aircraft is no longer in maintenance and has now
become "waste".
The interior of the aircraft is stripped and we endeavour
to recycle or seek a reuse avenue for all the interiors – some
parts, such as galley trollies and aircraft seats, will be reused
on other aircraft and other elements have ended up on
film sets or been reinvented as boardroom interiors and
furniture, for example. The possibilities are endless… all that
is needed is a good imagination!
The Teardown Phase
WITH THE interior stripped the remaining hull, which now
consists of mainly mixed metals, enters the teardown phase.
A heavy-tracked machine shears the hull into pieces for
loading onto bulk tippers for transport to a metal processing
facility, where it undergoes fragging and is processed further
into a number of waste streams. At this point normally
about eight percent by weight is classed as unrecyclable, ➥
ReproducedwithkindpermissionofCIWM.Visitwww.ciwm-journal.co.uk
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49

consisting of mainly fibrelam and sound-proofing material,
with small amounts of plastics, rubber and other odd
material which is normally sent for use as RDF.
The main material in the construction of aircraft 15
years or more old are aluminium alloys, stainless steel,
titanium, glass or reinforced polymer composites and
magnesium alloys. There are several tonnes of copper and
aluminium wiring, which is heavily shielded and not cost-
effective to remove, in addition to a number of different
plastics and fibreglass panels with honeycomb cores, made
from aluminium.
Newer aircraft are predominately made from carbon
composite materials, which are less prone to fatigue, don’t
corrode, are stronger and easier to make into airfoil or
complex shapes. These new composites will present new
challenges to the industry as we seek new methods of disposal.
Textiles from the seat covers, carpets and the insulation
also need a disposal route, and have ended up being reused
in other objects, from bags to sound-proofing. Other
materials, such as aircraft nickel-cadmium batteries, are
currently reused. Older aircraft have contained depleted
uranium and asbestos components and many still contain
beryllium alloys and cadmium coatings.
Presently the industry average for aircraft recycling is
achieving a rate of 80-85 percent. We at GJD Services Ltd
currently aim to achieve a recycle rate of at least 95 percent.
We have achieved a 99 percent recycle rate for an airline –
there is an additional cost element, but larger airlines are
willing to pay to reduce their carbon footprint as part of their
corporate environmental responsibility.
As part of the process one cabin interior was reused by
the marketing team to trial new products in the cabin. The
remaining hull and aircraft were parted out, depolluted, the
fuselage and wings were torn down and sent for recycling.
The process involved completely stripping out the aircraft
interior and finding a reuse or recycling stream for every
material including the wiring.
We sent some of the more problematic elements of the
interior to a specialist company that had found a method of
recycling the most challenging materials into a useful end
product, putting it through a saltus machine and additional
processes that allowed different plastics to be mixed, creating
an end product material that can be used in the manufacture
of such things as plastic pallets.
The Challenging Aspects
CURRENTLY, A typically problematic part of the recycling
process is the inside window reveal (the decorative panel
surrounding the cabin window) which has such a high grade
fire retardant finish, like all cabin interior items, it is very
difficult to recycle. A typical window panel is made up of 14
different components, made from 10 different materials,
which traditionally need to be segregated before they
can be recycled. It is a very labour-intensive process, not
commercially viable and to use these interior items as refuse
derived fuel is problematic, due to the fire retardant coatings.
Newer generation aircraft, such as the Airbus A380 and
Boeing’s new 787 Dreamliner, are constructed using carbon
fibre composites, which pose a new challenge for the industry
and we will have to approach these materials from a different
perspective, more akin to the disposal of asbestos due to the
fine fibres that can be released during the shredding process.
GJD is working with a team from Toyota and a number
of PhD students to develop scalable industrial methods
to take the aircraft and reduce the composite material
into manageable sizes in a safe, cost-effective and
environmentally controlled way, enabling the recycled
material to be used in future manufacturing.
The aerospace industry has begun thinking about aircraft
from design to disposal, with a cradle-to-grave approach,
and we are making great strides, engaging in the circular
economy, embracing new ideas and innovative approaches
throughout the entire lifecycle of an aircraft. <
Aine Spoors is the environment compliance
and ISO manager at GJD Services Ltd.
Having worked in the aircraft recycling
industry for the past eight years, she is
an advocate for raising standards within
the industry. Aine comes from a teaching
background and actively supports
research projects relating to her field.

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MK:OKThe soon-to-be-operational Milton Keynes Waste Recovery Park is putting circular
economy thinking into practice. The key players: Milton Keynes Council, Amey,
TOMRA Sorting Recycling and Stadler explain not just how the Park will work, but the
impact it will have… forget the concrete cows, MK is set to have a new attraction!
M
ilton Keynes Waste Recovery Park (MKWRP) is a
world-class waste treatment facility, which is due
to become fully operational in the near future.
The facility aims to deal with Milton Keynes’
black bag waste in a sustainable way by incorporating three
different types of treatment on one waste treatment site:
mechanical treatment (MT), advanced thermal treatment
(ATT) and anaerobic digestion (AD).
Annually, an estimated 132,000 tonnes of residual
municipal, or black bag, waste will be processed at the facility.
Around 50,000 to 80,000 tonnes of this will come from Milton
Keynes' households and other municipal waste the Council
collects. This material is currently sent to FCC’s 1m tonnes per
annum (tpa) landfill site in Bletchley, with a small proportion
of the waste processed in FCC’s "dirty" MRF, to recover some
materials and create a fuel, which is sent to the continent. The
remaining waste to be processed at the MKWRP will come
from neighbouring authorities and other local businesses.
Milton Keynes Council has set an ambitious but achievable
70 percent recycling target by 2024/25. The Council is
currently achieving a 52 percent recycling rate, well above the
national average of 44.9 percent, and further improvements
are expected when the MKWRP comes on stream. The current
national definition of recycling rate (NI 192) excludes some of
the outputs from the MKWRP and other treatment processes,
eg the recovery of rubble and hardcore, which are expected to
have a secondary use. Consequently, the Council has set two
separate recycling targets as shown in Table 1.
It has also introduced a "no mass burn" policy and
set a target to reduce the volume of waste it
sends to landfill to around five percent
by 2019/20, but may even achieve as low as three percent.
Key to achieving all three of these objectives is its ground-
breaking Waste Recovery Park, which is being built and will
be operated by Amey.
Mechanical Treatment
ONCE FULLY operational, the mechanical treatment (MT)
plant within the facility, which has been designed by Stadler
UK, will process some 70 tonnes per hour (tph) of black
bag residual waste. This waste stream contains a variety of
valuable, recyclable materials including mixed plastics, PET/
HDPE, bricks and rubble, cardboard, film and metals.
Milton Keynes Council and Amey have chosen to focus
on the recovery of three grades of plastics: PET, HDPE and
mixed plastics. In order to maximise the recovery of these
materials, the infeed material will firstly be screened to
separate out the organic fraction (fines of 70mm or below).
The high content of organic material is one of the biggest
challenges when treating municipal solid waste (MSW) and
can significantly affect the quality of the recyclables output,
so this organic matter will be targeted and removed
early on in the process, to be treated in an
anaerobic digestion
process on-site.
Once the
infeed
52

material has been screened, air knifes
will separate the light items from the
heavy and ballistic separators will be
used to separate the 2D (flat) material
from the 3D (rolling) items. The aim, in
following this process, is to ensure that
the material is in the best condition
possible for going on to the next stage
in the process.
Once this upfront mechanical
treatment has taken place, near infrared
(NIR) sorting technology, supplied by
TOMRA Sorting Recycling (TOMRA) will
be used to separate out three grades of
plastic: PET, HDPE and mixed plastics.
Given the nature of the black bag
infeed material at the plant, it would be
virtually impossible to sort and recover
materials such as plastics using manual
labour methods, both from health and
safety and a practical perspective.
However, optical sorting overcomes
these challenges and is able to operate
at 7tph, despite the dirty nature of the
infeed material.
One of TOMRA's AUTOSORT units
will separate and recover the plastics
by material size and colour, as required
by Amey for its end customers. Firstly,
the PET and HDPE will be targeted
and recovered at an exceptionally
high 94 percent purity rate. A further
AUTOSORT unit will target the
remaining mixed plastics. More than
90 percent of all plastics in the infeed
stream will be captured. These high
purity recovered materials will be sold
or reprocessed into new products.
Once the plastics have been
recovered, any remaining waste that
is neither recyclable nor compostable
will be used as a fuel for the Park’s
advanced thermal treatment (ATT)
plant. The gasification process used in
the ATT plant will create renewable
electricity, with around 5.8MW due
to be exported to the National Grid
annually. When coupled with the
electrical output from the anaerobic
treatment process, this will be enough
energy to power the equivalent of
around 11,000 homes.
Room For Fine-Tuning
ALTHOUGH MILTON Keynes Council
and Amey have chosen to focus
initially on the recovery of PET,
HDPE and mixed plastics, the NIR
sorting machines supplied by TOMRA
and Stadler can be programmed to
recover multiple fractions, if and
when they become economically and
environmentally viable, or in the event
of certain materials being banned from
thermal treatment. The mechanical
treatment plant can be "fine-tuned" to
remove, or leave in, certain materials
if Amey, the materials markets, the
AD or the ATT plant demand it. This
flexibility means that MKWRP is also
future-proofed in the event of other
packaging materials becoming more
prevalent in the future.
Andy Hudson, head of environment
and waste at Milton Keynes Council,
commented: "Our aim at MKWRP
is to take a holistic approach to the
management and treatment of waste.
Instead of landfilling vast amounts
of the black sack waste produced by
Milton Keynes’ households, we want to
divert this material from landfill and
use it to create energy.
"Also, with high costs associated
with incineration and high gate fees for
landfill, it makes commercial sense to
recover as much material from the waste
stream as possible, prior to landfill or
incineration. Ultimately, thanks to the
new plant, we will be able to reduce
our landfill to around just three percent
and significantly reduce our waste
management bills over the coming years."
Steve Almond, sales engineer at
TOMRA, added: “Milton Keynes Waste
Recovery Park is a prime example of the
approach that the UK’s waste industry
should be taking if we are to meet
the European Commission’s revised
Circular Economy Package 65 percent
recycling target, set for household
by 2030. Amey has recognised the
value of extracting as much recyclate
as possible for its clients, both on the
Milton Keynes project and on other
projects we are working on with Amey
and Stadler.
"Milton Keynes Council is
certainly leading the way in the UK
in terms of its treatment of MSW,
but the opportunities for material
recovery using sensor-based sorting
technology are even greater. Using a
combination of sensor-based sorting
technology, TOMRA’s equipment can be
programmed to identify and separate
each individual fraction, extracting
maximum value from MSW, diverting
material from landfill and increasing
recovery of materials for re-sale.
"We’re already working with
customers worldwide who are
recovering metals, plastics, paper,
ferrous and non-ferrous packaging,
films, paper, board and glass from MSW
at exceptionally high recovery and
purity rates." <
Target 2014/15 2019/20 2024/25
Updated recycling and composting target 1:
% of all waste collected by MKC that is recycled
55% 65% 70%
Updated recycling and composting target 2: % of household
waste recycled using National Indicator 192 definition
55% 60% 65%
Landfill target: maximum % of waste landfilled 37% 5% 5%
The pristine, soon-to-be-operational MKWRP above; and left, black bag waste collections in MK
Sponsored by
53

Get It SortedHave the Materials Facility (MF) Regulations resulted in more recyclable waste going to
landfill? This article sees Caroline Hand look into the problem of recycling contamination
R
ecycling collections do not often find their way into
the national news but, in January 2016, the BBC
reported on a worrying development. Oxfordshire
County Council is sending an increasing proportion of
its separately collected dry recyclables to energy from waste
(EfW) due to contamination by non-recyclable items. This is
surprising, seeing as South Oxfordshire is the best performing
council in England when it comes to municipal waste recycling
– the latest statistics (for 2014-15) indicate a rate of 67.3
percent, compared with the national average of 44.3 percent
(with neighbouring authorities West Oxfordshire and Vale of
White Horse are also high up on the league table).
During the BBC interview the blame for the higher rejection
rate was placed on the Environmental Permitting (England
and Wales) (Amendment) Regulations 2014, commonly
known as the MF (Materials Facility) or MRF (Materials
Recycling Facility) Regulations. But do these really require
larger quantities of materials to be rejected?
The MF Regulations
THE REGULATIONS were introduced to improve the overall
quality of recyclate and ensure that the recyclate from
commingled collections was of equivalent quality to that from
segregated collections, thus demonstrating compliance with
the Waste Framework Directive. The duties apply to MRFs that
receive more than 1,000 tonnes per year of waste containing
at least 50 percent by weight of two or more of the target
materials: glass, metal, plastic and paper and card.
Both inputs and outputs are subject to regular sampling,
the results of which must be reported to the Environment
Agency or Natural Resources Wales. This has prompted the
MRF operators to be more assiduous in their monitoring of the
incoming waste and their rejection of non-recyclable materials.
In each attempt to remove an unwelcome contaminant, such
as a nappy, several kilogrammes of genuine recyclables might
be scooped up. In Oxfordshire, these end up in the EfW facility
at a cost of around £70 per tonne.
After sampling the inputs the facility must report
"The Regulations were introduced to
improve the overall quality of recyclate and
ensure that the recyclate from commingled
collections was of equivalent quality to
that from segregated collections"

the average composition of target material, non-
target material (other recyclables) and non-recyclable
material. The quality of the outputs is left to the
market to determine, since the reprocessors specify
minimum quality standards in their contracts.
The most recent results on WRAP’s website relate to
September-December 2015. These show that for the 111
registered MRFs, the average percentage of target material in
inputs was 86 percent for England and 88.4 percent for Wales.
This means that in England, approximately 14 percent of the
“recycling” collected from householders could not be recycled.
The Real Villains
SO IS it fair to blame the MF Regulations for rising
contamination rates? The Regulations do not specify any
particular quality standards for the inputs and outputs, but
what is happening is that as a result of carrying out this
methodical sampling, the facility operators have a much more
accurate picture of contamination levels and are taking action
to remove contaminants.
The real villains are those who persistently place the wrong
items in their recycling bins, which can be for a variety of reasons:
• misunderstanding of what can and cannot be recycled
• failure to understand information, for example, through
inability to read or understand the language
• saving money (City of London residents pay for a residual
waste sack, but are given free recycling sacks)
• saving time (putting bulky or hazardous items in a
community recycling bin, rather than travelling to the
household waste recycling centre).
And sadly, there will always be some who have a deliberate
disregard for recycling, revealing their lack of awareness of the
benefits it brings.
All kinds of unwanted items find their way into the
recycling bins. In Oxfordshire, the main contaminants were
nappies and food waste. Pots, tubs and trays can also be a
problem since not all facilities can recycle them.
Detective work by some of our local authorities has
identified the prime suspects. In Manchester, the highest levels
of contamination came from apartment dwellers, but other
problem areas were characterised by:
• densely populated streets with small terraced houses
• privately rented accommodation
• transient population
• a mixture of commercial and residential buildings
• age – this plays a part too: students are typically the most
careless recyclers, with young families coming in second
from bottom.
Local authorities have taken two different approaches.
Several have focused on technological upgrades to the
materials facilities in order to improve the quality of their
output, and thus get a better deal from the reprocessors.
Others have focused on improving the quality of inputs
through better communication with residents.
Investment in new equipment can drastically improve the
performance of the MRF and some of the star performers have
been cited on WRAP’s website…
In Milton Keynes, about 40 percent of its residual stream
consisted of non-target but potentially recyclable polymers,
such as carrier bags, packaging film, food trays and yoghurt pots.
By investing in a manual picking cabin, it was able to segregate
these mixed plastics and succeeded in finding a buyer for them.
It subsequently invested in an optical sorting system.
In Exeter, high levels of contamination had placed the MRF
in danger of defaulting on its contract with a major paper
reprocessor. It solved the problem with a TiTech optical sorter.
And in Aldridge, which is one of only two materials
facilities in the country accredited to export directly to
China, it achieved this high standard through investment
in starscreens: steel shafts to which stars – spinning at up
to 2,500 revolutions per minute – are fitted. The screen
is inclined at an angle to the conveyor belt. Large two-
dimensional objects, such as cardboard, newspapers and
magazines are gripped and carried up the slope, while three-
dimensional objects like plastic bottles, metal cans and glass
roll out onto a separate belt.
Technology can also keep contaminants out of the bins. In
Slough, the communal recycling bins can only be opened with
a fob issued to residents of the flats. This prevents passers-by
from casually dumping other waste items.
The Talking Cure
KEEP BRITAIN Tidy carried out an exercise with a citizen’s
jury – a representative group of ordinary citizens who, over a
period of time, were taught about recycling and encouraged
to describe their evolving viewpoints. Through this learning
process, they became more committed recyclers (see The Ur-
bin Issue, a joint project between Keep Britain Tidy and Sita1).
A key conclusion was that people will be more motivated
to recycle if they can see the benefits at a local level, if income
from recycling is spent on improving local parks, for example.
To catch those students before they start contaminating
the bins, many local authorities have produced materials
especially for schools and will hold special lessons on the
theme of recycling.
Sometimes the authority just needs to provide clearer
information. Simple pictorial stickers – like a crossed out
nappy – are more effective than long, wordy leaflets. People
also respond better to specific descriptions, eg a “shampoo
bottle” rather than "PET". Hopefully one of the benefits of
the MF Regulations is that they will reveal trends in input
quality, giving a clearer picture of the strategies which are
most effective. <
Reference
1. ww.sita.co.uk/downloads/TheUrbinIssueReport-1408-
web.pdf)
Caroline Hand MSc is a freelance writer specialising in waste
and resources. She has been writing about
environmental law and policy for more than
20 years. She is also an experienced CIWM
WasteSmart trainer; her business, Crich
Environment Health and Safety Training, offers
Foundation and Advanced courses alongside waste
training tailored to individual business needs.
Sponsored by
55

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