Document 2XB6dE7a5EVE9q7akj6ZXxp6

Response ID ANON-75K5-1Z7Q-Y Submitted to Consultation on potential amendments to the Persistent Organic Pollutants (POPs) Regulation Submitted on 2023-04-27 19:54:39 About you 1 Would you like your response to be confidential? (Required) No Reason for confidentiality: 2 What is your name? What is your name?: (Redacted) (Redacted) 3 What is your email address? If you enter your email address, then you will automatically receive an acknowledgement email when you submit your response. Email address: (Redacted) @ (Redacted) .co.uk 4 Are you responding as an individual or on behalf of an organisation? Organisation 5 What type of organisation are you responding on behalf of? Other (please specify) Other: Professional Membership Organisation 6 If you are responding on behalf of an organisation, what is the name of the organisation? organisation name: CIWM 7 Where in the UK are you/your organisation based and/or in operation? (tick all that apply) England, Wales, Scotland, Northern Ireland, Outside the UK (EU) Waste limits (i) - Perfluorooctanoic acid (PFOA) 8 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) How would this change impact (PFOA WL (i)): Many of CIWM members will be handling and treating waste from the industrial sector and this may well include food processing equipment, at the end of its useful life. PFOA formed from inadequate incineration of fluoropolymers from municipal solid waste incineration is of concern to some of CIWM's members. If as indicated in the consultation PFOA requires high temperature incineration, CIWM believes there is limited capacity for this treatment process. 9 To what extent do you agree or disagree with our proposed waste limit for PFOA (1mg/kg for PFOA and its salts (or 0.025 mg/kg in AFFF); 40mg/kg for PFOA related compounds (or 1 mg/kg in AFFF))? Agree 10 Please explain the reasons for your answer to question 9, with reference to evidence and/or possible alternative options where relevant Explain sentiment PFOA WL (i): CIWM is concerned about the limits in relation to robustness of checking limits for this POP, considering its use and stated detection on microwave popcorn bags, food, etc. For the resources and waste sector to check limits on such small items as popcorn bags would be impractical and likely to be inaccurate. This waste stream is very likely to be treated via municipal incineration. 11 There is a lack of concentration data for PFOA in waste in the UK so our assessment carries a level of uncertainty. Our evidence-based judgement is that PFOA is unlikely to be found at a level exceeding 1mg/kg in waste (excluding firefighting foams and hydraulic fluids). Are you aware of any evidence to suggest other sectors and/or products where PFOA would fall above or below the proposed waste concentration limit level? Please provide details if so including with reference to tonnages, concentration levels, ability to segregate waste, and impacts where possible. There is a lack of concentration data for PFOA in waste in the UK so our assessment carries a level of uncertainty. Our evidence-based judgement is that PFOA is unlikely to be found at a level exceeding 1mg/kg in waste (excluding firefighting foams and hydraulic fluids). Are you aware of any evidence to suggest other sectors and/or products where PFOA would fall above or below the proposed waste concentration limit level? Please provide details if so including with reference to tonnages, concentration levels, ability to segregate waste, and impacts where possible.: CIWM is unaware of any evidence. 12 There are expected to be one-off impacts for organisations who hold PFOA containing waste to familiarise themselves with the new regulations and procedures, and the time taken to source appropriate disposal routes. Are you aware of how long (in hours) this will take, and any costs incurred? Please provide details if so. There are expected to be one-off impacts for organisations who hold PFOA containing waste to familiarise themselves with the new regulations and procedures, and the time taken to source appropriate disposal routes. Are you aware of how long (in hours) this will take, and any costs incurred? Please provide details if so. : 13 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. : 14 For hydraulic fluids, are you aware of any evidence to suggest where PFOA falls above or below the proposed waste concentration limit level? Please provide details if so, including with reference to tonnages, concentration levels, ability to segregate waste and other impacts where possible. For hydraulic fluids, are you aware of any evidence to suggest where PFOA falls above or below the proposed waste concentration limit level? Please provide details if so, including with reference to tonnages, concentration levels, ability to segregate waste and other impacts where possible. : 15 The study team for the EU Impact Assessment suggest that detecting PFOA at a concentration limit of 1mg/kg is economically feasible. Are you aware of any evidence regarding potential financial cost to test and segregate waste streams at this level? Please provide details if so. Waste containing PFOA above the waste concentration limit will require high temperatures to destroy the POP, for example, in a hazardous waste incinerator or suitable cement kiln. Are you aware of any evidence regarding potential financial cost (gate fees) to destroy this waste? Please provide details if so The study team for the EU Impact Assessment suggest that detecting PFOA at a concentration limit of 1mg/kg is economically feasible. Are you aware of any evidence regarding potential financial cost to test and segregate waste streams at this level? Please provide details if so Waste containing PFOA above the waste concentration limit will require high temperatures to destroy the POP, for example, in a hazardous waste incinerator or suitable cement kiln. Are you aware of any evidence regarding potential financial cost (gate fees) to destroy this waste? Please provide details if so : CIWM is aware that high temperature incineration can be around 2,000 per tonne. For wastes that also have an added complexity this can be as much as 6,000. With more waste streams potentially containing POPs these costs are likely to keep increasing as capacity becomes more of an issue. Not just in the UK. 16 Do you have any further evidence to suggest the suitability, or otherwise, of introducing waste concentration limits specific to one type of waste (such as aqueous film forming foams (AFFF))? Please provide details if so. Do you have any further evidence to suggest the suitability, or otherwise, of introducing waste concentration limits specific to one type of waste (such as aqueous film forming foams (AFFF))? Please provide details if so. : Waste limits (ii) - Perfluorohexane sulfonate (PFHxS) 17 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) Is this proposal of particular importance to you and/or the organisation you represent? : CIWM members are likely to end up handling and treating waste items that could contain this POP, particularly textiles, leather and upholstery. 18 To what extent do you agree or disagree with our proposed waste limit for PFHxS (1mg/kg for PFHxS and its salts; 40mg/kg for PFHxS related compounds)? Agree 19 Please explain the reasons for your answer to question 18, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant : CIWM is concerned about the robustness of detection for this POP, especially if its use is in furniture, the issue of detecting POPs in waste domestic upholstery has shown this is not an easy or reliable task. 20 There is a lack of concentration data for PFHxS in waste in the UK so our assessment carries a level of uncertainty. Our evidence-based judgement is that PFHxS is unlikely to be found at a level exceeding 1mg/kg in waste (excluding firefighting foams/hydraulic fluids). Are you aware of any evidence to suggest other sectors and/or products where PFHxS would fall above or below the proposed waste concentration limit level? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels, ability to segregate waste, and other impacts where possible. There is a lack of concentration data for PFHxS in waste in the UK so our assessment carries a level of uncertainty. Our evidence-based judgement is that PFHxS is unlikely to be found at a level exceeding 1mg/kg in waste (excluding firefighting foams/hydraulic fluids). Are you aware of any evidence to suggest other sectors and/or products where PFHxS would fall above or below the proposed waste concentration limit level? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels, ability to segregate waste, and other impacts where possible. : 21 For hydraulic fluids, are you aware of any evidence to suggest where PFHxS falls above or below the proposed waste concentration limit level? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels, ability to segregate waste, and other impacts where possible For hydraulic fluids, are you aware of any evidence to suggest where PFHxS falls above or below the proposed waste concentration limit level? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels, ability to segregate waste, and other impacts where possible : 22 There are expected to be one-off impacts for organisations who hold PFHxS containing waste to familiarise themselves with the new regulations and procedures, and the time taken to source appropriate disposal routes. Are you aware of how long (in hours) this will take, and any costs incurred? Please provide details if so. There are expected to be one-off impacts for organisations who hold PFHxS containing waste to familiarise themselves with the new regulations and procedures, and the time taken to source appropriate disposal routes. Are you aware of how long (in hours) this will take, and any costs incurred? Please provide details if so. : 23 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. : 24 The study team for the EU Impact Assessment suggest that Limits of Detection of 1mg/kg is economically feasible. Are you aware of any evidence regarding potential financial cost to test and segregate waste streams at this level? Please provide details if so The study team for the EU Impact Assessment suggest that Limits of Detection of 1mg/kg is economically feasible. Are you aware of any evidence regarding potential financial cost to test and segregate waste streams at this level? Please provide details if so : The recent experience of detecting POPs in domestic soft furnishings has shown this to be a difficult task, requiring specific training and equipment. The cost of equipment and need to train employees has been found to be unviable for individual large companies and so impossible for smaller business to even contemplate. Segregation for WUDS (waste upholstered domestic seating) showed segregation to be complex and the tonnage arising from assumption of containing POPs to warrant temporary storage whilst facility capacity is found. If as indicated in the consultation document these POPs need high temperature incineration, this is more limited than municipal facilities, potentially requiring longer storage before final treatment. CIWM is aware that the two high temperature facilities in the UK are old and there is no indication of planning new, additional or replacement facilities. 25 Waste containing PFHxS above the waste concentration limit will require high temperatures to destroy the POP, for example, in a hazardous waste incinerator or suitable cement kiln. Are you aware of any evidence regarding potential financial cost (gate fees) to destroy this waste? Please provide details if so. Waste containing PFHxS above the waste concentration limit will require high temperatures to destroy the POP, for example, in a hazardous waste incinerator or suitable cement kiln. Are you aware of any evidence regarding potential financial cost (gate fees) to destroy this waste? Please provide details if so. : CIWM is aware that high temperature incineration can be around 2,000 per tonne. For wastes that also have an added complexity this can be as much as 6,000. With more waste streams potentially containing POPs these costs are likely to keep increasing as capacity becomes more of an issue. Not just in the UK. 26 Do you have any further evidence to suggest the suitability, or otherwise, of introducing waste concentration limits specific to one type of waste (such as aqueous film forming foams (AFFF))? Please provide details if so. Do you have any further evidence to suggest the suitability, or otherwise, of introducing waste concentration limits specific to one type of waste (such as aqueous film forming foams (AFFF))? Please provide details if so. : Waste limits (iii) - Short Chain Chlorinated Paraffins (SCCPs) 27 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) 28 To what extent do you agree or disagree with our proposed waste limit for SCCPs (1,500 mg/kg)? Agree 29 Please explain the reasons for your answer to question 28, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer to question 28, with reference to evidence and/or possible alternative options where relevant: Response to Question 27 - CIWM members are likely to end up handling and treating waste items like plastics and rubber. The consultation document and subsequent questions do not mention any lack of concentration data in the UK but does assume due to the testing difficulty "...that all waste will have to be determined by material type or use...", CIWM asks how those in the resources and waste sector are to know which items these are likely to be, as plasticizer in plastics, for example will cover multiple products. All this potentially leads to a large tonnage of material to find capacity for treatment. 30 Are you aware of any evidence to help determine whether SCCPs may fall above or below the waste concentration limit of 1500mg/kg in the UK? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels, ability to segregate wastes, and other impacts where possible. Are you aware of any evidence to help determine whether SCCPs may fall above or below the waste concentration limit of 1500mg/kg in the UK? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels, ability to segregate wastes, and other impacts where possible. : 31 Do you have evidence of the tonnage of waste containing SCCPs in the UK and how they are currently disposed of (landfill, recycling, Energy from Waste)? Please provide details if so. Do you have evidence of the tonnage of waste containing SCCPs in the UK and how they are currently disposed of (landfill, recycling, Energy from Waste)? Please provide details if so. : 32 Are you aware of any anticipated costs for disposing of SCCPs contaminated waste (such as incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? If so, please provide any supporting evidence. Are you aware of any anticipated costs for disposing of SCCPs contaminated waste (such as incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? If so, please provide any supporting evidence. : Even though this consultation suggests treatment in municipal waste incineration facilities, the experience of waste upholstered domestic seating (WUDS) has shown the costs can increase extensively - CIWM members and others in the sector have indicated an increase to 300 a tonne and items like mining conveyor belts are heavy, due to the role they must perform and the size of them. This will mean shredding before adding to the incinerator feedstock, and such treatment will need specific controls on emissions, as their long-range environmental transport will be an issue. All adding to costs for handling and treatment. If some of the equipment and controls as introduced for WUDS can be utilised, this will save some costs. Experience with WUDS has shown that it does take time to look at how waste streams are handled, what needs to be performed differently, what equipment needs ordering, commissioning time as well as procedures put in place. There are added costs and timings with the ordering of equipment, changing processes at sites and capacity for treatment. Sufficient time will be required by the resources and waste sector to implement changes and the processes, and CIWM suggests the learnings from the soft furnishings implementation shows that working with the sector can achieve results. 33 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. : 34 Are you aware of any evidence to suggest that a lower waste concentration limit would be achievable in the UK with regards to technical and economic feasibility? Please provide details if so, including with reference to current and/or future limits of detection for SCCPs in waste. Are you aware of any evidence to suggest that a lower waste concentration limit would be achievable in the UK with regards to technical and economic feasibility? Please provide details if so, including with reference to current and/or future limits of detection for SCCPs in waste. : Waste limits (iv) - Polybrominated diphenyl ethers (PBDE) 35 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) why important PBDE WL (iv): CIWM members are already impacted with this family of POPs through DecaBDE in WUDS and WEEE plastics. WUDS and the use of the term waste meant that some items that could have been reused were lost directly to the waste treatment process - destroying the POPs present but reducing the possibility of a more circular economy for some household items. 36 To what extent do you agree or disagree with our proposed waste limit for PBDE (350 mg/kg, dropping to 200 mg/kg 5 years after entry into force)? Agree 37 Please explain the reasons for your answer to question 36, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer to question 36, with reference to evidence and/or possible alternative options where relevant: CIWM fully supports the removal of chemicals of concern but as WUDS and POPs like DecaBDE showed, analysis for such chemicals is complicated and costly. XRF is one of the analysis methods, but it is not 100% reliable as other similar elements could interfere with the result. It is not quantitative enough and the level of competence required to use indicates to CIWM it is not suitable for the resources and waste sector to use. Lowering the limit in a way will make little difference to WUDS as the current assumption is all WUDS have PDBE POPs. 38 Based on current EA evidence, decreasing the PBDE waste limit to 200mg/kg in GB is expected to have no/minimal additional impacts on WEEE/ELV plastic recycling, compared to existing waste limits. Are you aware of any evidence to either support or oppose this? Please provide details if so. Based on current EA evidence, decreasing the PBDE waste limit to 200mg/kg in GB is expected to have no/minimal additional impacts on WEEE/ELV plastic recycling, compared to existing waste limits. Are you aware of any evidence to either support or oppose this? Please provide details if so. : CIWM presupposes that WEEE/ELV plastic recycling assumes that all such material will contain POPs and need to be treated via incineration. Unless the testing is more accurate and easier to perform this will always be the assumption if there is no indication before the material is deemed waste to indicate that POPs are not present - such as a certificate of clean health. 39 Are you aware of any evidence to indicate the presence of PBDE in CDW plastics and textiles, and/or other waste streams or sectors? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels and impacts where possible. Are you aware of any evidence to indicate the presence of PBDE in CDW plastics and textiles, and/or other waste streams or sectors? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels and impacts where possible.: PBDE is noted as being used in carpets, CIWM is aware this is usually applied at the thread stage, so cheaper nylon-based carpets are those likely to be impacted, if they are still in circulation since the 2017 listing. The issue is the POP is likely to be walked out of the item on shoes. CIWM believes that flame retardant in the UK for domestic carpet is not required but there might be some public buildings that have flame retardant carpets. Trade waste from upholstery manufacturers should have data-sheet information provided or if asked to declare the waste stream POPs free, should supply this information prior or certainly when asked by the resources and waste sector - likely to be on assessment of the waste stream. 40 Are there any additional costs you anticipate for disposing of PBDEs contaminated waste under the proposed waste limit (such as incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? If so, please can you provide any supporting evidence. Are there any additional costs you anticipate for disposing of PBDEs contaminated waste under the proposed waste limit (such as incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? If so, please can you provide any supporting evidence. : If carpets become part of this waste stream, CIWM suggests early engagement with the resources and waste sector as this is a bulky waste stream that will need additional handling (shredding and its associated costs) before treatment in municipal incineration. Experience with WUDS has shown that it does take time to look at how waste streams are handled, what needs to be performed differently. There are added costs and time with the ordering of equipment, changing processes at sites and capacity for treatment. CIWM members and others in the sector have indicated an increase to 300 a tonne for municipal incineration and there are extra costs due to segregation, storage prior to treatment and emissions control. 41 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known.: Waste Limits (v) - Pentachlorophenol (PCP) 42 Is this proposal of particular importance to you and/or the organisation you represent? I don't know importance reason PCP WL (v): 43 To what extent do you agree or disagree with our proposed waste limit for PCP (100 mg/kg)? Agree 44 Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant : CIWM notes the limit has already been accepted at previous BRS COP. 45 Based on current evidence, we anticipate the economic costs of introducing the proposed waste limit for PCP in GB to be none/minimal. Are you aware of any evidence to either support or oppose this view? Please provide details if so, including with reference to gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc. Based on current evidence, we anticipate the economic costs of introducing the proposed waste limit for PCP in GB to be none/minimal. Are you aware of any evidence to either support or oppose this view? Please provide details if so, including with reference to gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc. : 46 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known.: Waste limits (vi) - Dioxins, Furans, and dioxin-like PCBs 47 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) importance reason dioxins WL (vi): 48 To what extent do you agree or disagree with our proposed position to include dioxin-like PCBs in the dioxins and furans waste concentration limit? Not Answered 49 Please explain the reasons for your answer to question 48, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant : Reason for yes in Question 47 - CIWM is aware that emission controls on incineration facilities monitor these outputs as part of their BAT requirements. 50 To what extent do you agree or disagree with our proposed waste concentration limit for dioxins, furans, and dioxin-like PCBs (0.005 mg TEQ/kg, including dioxin-like PCBs)? Not Answered 51 Please explain the reasons for your answer to question 50, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant : 52 Based on current evidence, we anticipate the economic impacts of decreasing the dioxins and furans waste limit to 0.005 TEQ/kg in GB to have limited impacts on biomass incinerator APCR and no impacts on domestic ash. Are you aware of any evidence to either support or oppose this view? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels and impacts where possible. Based on current evidence, we anticipate the economic impacts of decreasing the dioxins and furans waste limit to 0.005 TEQ/kg in GB to have limited impacts on biomass incinerator APCR and no impacts on domestic ash. Are you aware of any evidence to either support or oppose this view? Please provide details if so, including with reference to relevant waste streams, tonnages, concentration levels and impacts where possible. : 53 The EU Impact Assessment identifies approximately 20 waste streams where dioxins and furans can be found, primarily in waste streams related to combustion activities. Are you aware of any other waste streams that are likely to be impacted by a lower waste concentration limit value? Please provide details if so. The EU Impact Assessment identifies approximately 20 waste streams where dioxins and furans can be found, primarily in waste streams related to combustion activities. Are you aware of any other waste streams that are likely to be impacted by a lower waste concentration limit value? Please provide details if so. : 54 Are there any additional costs you anticipate for disposing of PCDD/F waste under the proposed waste limit (such as gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? Please provide details if so. Are there any additional costs you anticipate for disposing of PCDD/F waste under the proposed waste limit (such as gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? Please provide details if so. : 55 There is limited analytical information available on the concentration of dioxin- like PCBs in waste and the amount of waste that would be diverted to different treatments under the lead waste limit option. Are you aware of any evidence regarding relevant waste streams, tonnages, concentration levels, ability to segregate waste, and associated costs (such as gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? Please provide details if so. There is limited analytical information available on the concentration of dioxin- like PCBs in waste and the amount of waste that would be diverted to different treatments under the lead waste limit option. Are you aware of any evidence regarding relevant waste streams, tonnages, concentration levels, ability to segregate waste, and associated costs (such as gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? Please provide details if so. : 56 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known.: Waste limits (vii) - Dicofol 57 Is this proposal of particular importance to you and/or the organisation you represent? I don't know importance reason dicofol WL vii: 58 To what extent do you agree or disagree with our proposed waste limit for dicofol (50mg/kg)? Agree 59 Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer, with reference to evidence and/or possible alternative options where relevant : CIWM would only have members involved in the destruction of these POPs if there were unused pesticide that had to be destroyed. 60 Based on current evidence, we anticipate the economic costs of lowering the dicofol waste limit in GB to be zero or minimal. Are you aware of any evidence to either support or oppose this view, including with reference to costs such as gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? Please provide details if so. Based on current evidence, we anticipate the economic costs of lowering the dicofol waste limit in GB to be zero or minimal. Are you aware of any evidence to either support or oppose this view, including with reference to costs such as gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc)? Please provide details if so. : 61 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known.: Waste limits (viii) - Hexabromocyclododecane (HBCDD) 62 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) importance reason HCB WL (viii): The resources and waste sector is likely to only see this waste stream if older construction and demolition waste arises. 63 To what extent do you agree or disagree with our proposed waste limit for HBCDD (500 mg/kg)? Agree 64 Please explain the reasons for your answer to question 63, with reference to evidence and/or possible alternative options where relevant Please explain the reasons for your answer to question 63, with reference to evidence and/or possible alternative options where relevant: Without knowing the extent of this waste stream arising, CIWM cannot comment further but is willing to assist Defra if the need arises to determine the extent of this waste stream, with CIWM members involved in the construction and demolition waste sector. As indicated in Annex A of the consultation document HBCCD has been found in WUDS and the accurate analysis of this POP has meant an assumption of presence and the waste steam treated as such. There are some operators that are looking to remove the offending soft furnishing from the solid frame but this has handling issues which add to the cost of dismantling to reduce the overall tonnage for treatment. 65 Based on current evidence, we anticipate the economic costs of lowering the HBCDD waste limit in GB to be minimal for all waste streams. Are you aware of any evidence to either support or oppose this view, including with reference to costs such as incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc? Please provide details if so. Based on current evidence, we anticipate the economic costs of lowering the HBCDD waste limit in GB to be minimal for all waste streams. Are you aware of any evidence to either support or oppose this view, including with reference to costs such as incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes etc? Please provide details if so.: 66 Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known. Are you aware of any other organisations that may be impacted by this proposal? Please provide details if so, including references to the number of organisations, types of organisations (Local Authorities, businesses, independent or public bodies), size (micro, small, medium or large), and the anticipated impacts, if known.: Waste limits (ix) - UV328, Dechlorane Plus, and Methoxychlor 67 Is this proposal of particular importance to you and/or the organisation you represent? Yes (please specify how below) importance reason WL (ix): Dechlorane Plus's use in thermoplastics and thermosets mean they are likely to enter the resources and waste stream at the end of life of the product they have been used in. UV-328 has a wide range of uses (paints and coatings for plastic, including goods packaging; liquid crystal panels) that will ensure items eventually end up with the resources and waste sector. 68 Are you aware of any evidence to suggest a waste concentration limit value for UV-328 that would be suitable for adoption within GB if and/or when this substance is adopted as a POP by the Stockholm Convention? Please provide details if so, including with reference to data sources, timescales, tonnages impacted and potential costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. Are you aware of any evidence to suggest a waste concentration limit value for UV-328 that would be suitable for adoption within GB if and/or when this substance is adopted as a POP by the Stockholm Convention? Please provide details if so, including with reference to data sources, timescales, tonnages impacted and potential costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. : CIWM believes the robustness of testing is essential, along with certificates/markings that state the items have a clean bill of health, i.e., do not have UV-328. As UV-328 is used in paint any items arriving at HWRCs, like externally painted wood, will mean an increase in costs due to treatment for hazardous waste. As noted in many of the responses here the time and procedures to segregate this waste will be determined by the item that UV-328 contaminates and how easy that waste is to remove from other items. What storage is needed in case the disposal route capacity is limited or constrained. This POP has wide usage, including liquid crystal displays and this is used in measuring instruments, testing equipment and heads up displays. Segregation in some sectors will be easier than others but having an indication of absence of such a POP would be advantageous. The treatment method will determine the cost of disposal, so for high temperature incineration a cost of at least 2,000 a tonne. This will be in addition to any pre-treatment (e.g., shredding) that may be required. With more waste streams potentially containing POPs these costs are likely to keep increasing as capacity becomes more of an issue. Not just in the UK. 69 Are you aware of any evidence to suggest a waste concentration limit value for Methoxychlor that would be suitable for adoption within GB if and/or when this substance is adopted as a POP by the Stockholm Convention? Please provide details if so, including with reference to data sources, timescales, tonnages impacted and potential costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. Are you aware of any evidence to suggest a waste concentration limit value for Methoxychlor that would be suitable for adoption within GB if and/or when this substance is adopted as a POP by the Stockholm Convention? Please provide details if so, including with reference to data sources, timescales, tonnages impacted and potential costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. : CIWM can envisage this waste stream arising from disposal of unwanted stock, etc. and so putting a cost on that is complicated as it will depend on disposal route, tonnage arising and capacity available to treat. 70 Are you aware of any evidence to suggest a waste concentration limit value for Dechlorane Plus that would be suitable for adoption within GB (if and/or when this substance is adopted as a POP by the Stockholm Convention)? Please provide details if so, including with reference to data sources, timescales, tonnages impacted and potential costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. Are you aware of any evidence to suggest a waste concentration limit value for Dechlorane Plus that would be suitable for adoption within GB (if and/or when this substance is adopted as a POP by the Stockholm Convention)? Please provide details if so, including with reference to data sources, timescales, tonnages impacted and potential costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. : CIWM believes the robustness of testing is essential, along with certificates/markings that state the items have a clean bill of health, i.e., do not contain Dechlorane Plus. As noted in many of the responses here the time and procedures to segregate this waste will be determined by the item that Dechlorane Plus contaminates and how easy that waste is to remove from other items. What storage is needed in case the disposal route capacity is limited or constrained. As the bulk of this POP is used in wire harnesses for the automotive and aviation sector, segregation should be straight forward. The difficulty will arise for amateur car renovations. CIWM is aware that critical medical equipment uses Dechlorane Plus within the wiring and any other competent that needs protecting from heat and so potential to catch fire. Such equipment have long lifetime of use. The treatment method will determine the cost of disposal, so for high temperature incineration a cost of at least 2,000 a tonne. This will be in addition to any pre-treatment (e.g., shredding) that may be required. With more waste streams potentially containing POPs these costs are likely to keep increasing as capacity becomes more of an issue. Not just in the UK. Waste limits (x) - Other POPs 71 Are you aware of any evidence to suggest that any of the other waste concentration limits listed in the POPs Regulation should be amended in upcoming or future legislation? Please provide details if so, including with reference to specific substances, data sources, timescales, tonnages impacted and potential financial costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. Are you aware of any evidence to suggest that any of the other waste concentration limits listed in the POPs Regulation should be amended in upcoming or future legislation? Please provide details if so, including with reference to specific substances, data sources, timescales, tonnages impacted and potential financial costs (including incineration gate fees, administrative costs or time taken to familiarise with the requirements and sourcing disposal, testing, segregation, storage of wastes), if known. : Any other comments or evidence to share? 110 Please use this space if you have any other comments or evidence that you would like to share relating to this consultation. Please use this space if you have any other comments or evidence that you would like to share relating to this consultation.: CIWM is fully aware of the effort to implement new policy and changes to regulation and supports the move to protecting human health and the environment from chemicals of concern. As the implementation of POPs in soft furnishings showed, even a limited change - no longer able to be landfilled - impacted extensively on the resources and waste sector. CIWM hopes that everyone can learn from this - including the resources and waste sector trying to pre-empt possible changes due to chemicals being added under the Stockholm Convention. One of the main concerns highlighted to CIWM is the limits on testing that is indicated within the consultation document and subsequent regulations. It is not just equipment, it is competent personnel, training requirements, and methodology. As research for the soft furnishings showed that XRF as a test method had its limits, including masking by other chemicals present. Are there ways to gain confirmation from manufactures besides safety data sheets, alongside markings on items showing data of manufacture (not on parts that are easily removed). This will be important for items that gain derogations due to their importance - aviation sector for Dechlorane Plus or car manufacturers for UV-328; such items could be in circulation for longer. Other issues include segregation. Many of the uses of the POPs indicated in this consultation are for cabling, textiles, plastics and foams used in construction, electronic items. Operators collecting these items, whether at the kerbside from domestic properties or within usual commercial collections will have to determine the most appropriate segregation methods. Items that arise in skips, due to house renovations (rewiring) or office refits will need consideration, cabling, electronic equipment are items that might well arise and need testing or treating regardless of content. Easier identification, at source, will help producers and collectors, how this manifests itself could be key to easier segregation. Treatment capacity for incineration and high temperature incineration is not optimised and experience from the soft furnishing changes showed that capacity that is currently based around local authority collection may not be the ideal format - as more of the material streams come from commercial waste, CIWM's members and others working in the resources and waste sector have to consider alternative routes of treatment and disposal. Pressure from Net Zero and carbon targets for local authorities and other public bodies like the NHS make for difficult decisions. Wales and Scotland are looking to limit incineration to 5%, what are the implications on waste streams like those containing POPs? Also, these countries do not have high-temperature incineration, so it will all be diverted to England. Other countries like Northern Ireland and Ireland already have limited capacity. CIWM believes a lot of learning can come from the soft furnishings situation and working together on solutions was a commendable way forward. CIWM is taking on some forward thinking through some new group structure and using its members knowledge to try and plan ahead for such eventualities but the sector will need a heads up from policy leads that such changes are likely to come and what that might mean, so that the resources and waste sector can start planning and preparing for changes or adapting technology to accommodate temporary changes in tonnage. CIWM is concerned as noted above about influence from other areas, Net Zero, carbon targets, etc. so situations that warrant such change should ideally be based on robust evidence - not that the POP should be listed but any methodology used to determine action. CIWM is aware after attending a webinar on Dechlorane Plus and UV-328 proposed for listing in Annex A to the Stockholm Convention that the UK is carrying out research on Dechlorane Plus that might well influence decisions. Is there a way for this information to be more widely available or if such studies are being undertaken that there is some communication to impacted sectors. The consultation document indicates that some studies are based on four samples, how statistically significant is such testing and how does this relate across all the waste streams. One of the impacts is on the circular economy, reuse is a key factor to keeping items `working' for longer and certainly in soft furnishings the mixed messages that were received led to items normally being reused going straight to disposal. CIWM agrees there is no need to panic the public about POPs and their use, but reuse is hampered by the public not wanting to buy a `toxic' second-hand sofa. Organisations in the reuse sector are already looking to the long term, moving to single contractors to limit the price increases and enable better support. But they are having to educate drivers to change the criteria for collection from house-clearances; if the item is not guaranteed to resell, it is not going to be picked up. This increases the tonnage collected at HWRC or collected by skips, increasing the need for capacity to treat. Also, any items that might go down the local authority route, with a concession for disposal is now lost - certainly for soft furnishings. CIWM also believes there needs to be better understanding of which type of items are included - fire regulations dictate the level of retardant required for many items. CIWM asks what considerations have been given for fly-tipping or increases in waste crime. Increased prices for items to be disposed of is likely to attract the criminal mind, higher disposal prices, more money to be made - leading to fly-tipped waste. The cost then to local authorities for picking up items that will have an increased cost of disposal, and subsequent impact on budgets. CIWM is fully aware that any changes will have an impact on permits and contracts - another area that effect budgets, and not just for local authorities. CIWM is aware of other items using fire retardant chemicals, like mattresses or PFAS chemicals for stain-proofing or waterproofing (textiles). Design is one aspect of limiting the tonnage for treatment, but this must be performed in a way that does not impact on human health or the environment. Mattress and textile recycling are areas of growth or stabilisation so confirmation of a `clean bill of health' would assist any recycling of components. Mattress are being broken down to retrieve metal and fibre. Clothing is being taken back to thread. Both need consideration in context of circular economy, business viability and carbon reduction but potential recirculation of POPs (if contained). CIWM suggests government could assist with holding a database of historical information from manufacturers, enabling checking of older items to determine POPs contamination. Producer Responsibility (PR) has been raised for textiles already to prevent unsustainable materials being used and PR for packaging to increase recyclability is closer than it was in the past. CIWM asks, should government be looking at how it can utilise producer responsibility in the context of POPs themselves or manufacturers that still use them. If applied on the POPs themselves this should drive more environmentally friendly options to be considered. Manufacturers that still use them under derogations may look to find alternatives, quicker. CIWM is aware that this is already the case in the aviation sector, seeking alternatives to Dechlorane Plus in engines. Consultee Feedback on the Online Survey 111 Overall, how satisfied are you with our online consultation tool? Satisfied 112 Please give us any comments you have on the tool, including suggestions on how we could improve it. Please give us any comments you have on the tool, including suggestions on how we could improve it. :