The Environment Agency is considering plans to allow greatly increased levels of hazardous waste to be burnt as fuel in cement and lime kilns [1]. The move, which would allow waste from pharmaceutical, pesticide, biocide and explosives manufacturing to be burnt without consultation with the nearby local community, is opposed by Friends of the Earth. A public consultation on the Agency's plans ends on Friday (18 June).

The proposal would bring benefits for the Government and cement industry:

The Government is under pressure to reduce the amount of toxic material that is landfilled. The EU landfill directive, which comes into force on 16 July, will leave the UK with only 12 sites capable of processing hazardous waste. These sites will be unable to deal with the estimated 5.2 million tonnes of hazardous waste produced each year.

The energy-intensive cement industry is keen to burn hazardous waste as it is cheaper than conventional fuel. Kilns already burn around 150,000 tonnes of `substitute fuels', including chemical waste, tyres and sewage sludge.

Friends of the Earth opposes the plans because:

Friends of the Earth's waste campaigner Anna Watson said:

"Local communities will be understandably concerned about plans to allow cement kilns to burn hazardous waste in their area without any public consultation. The Government has got a problem dealing with the amount of hazardous waste created, but the solution is not to sell it off as cheap fuel. There should be strong incentives to reduce its production instead. The environment and local people must be put ahead of the interests of big business."

1. http://www.environment-agency.gov.uk/yourenv/consultations/743155/?version=1&lang=_e

A briefing follows:

Introduction

The cement/ lime industry is set to burn greatly increased levels of hazardous waste. Under proposals issued by the Environment Agency, cement and lime kilns will be allowed to burn a broader range of hazardous waste substances. This includes waste derived from the manufacture of pharmaceuticals, pesticides, biocides and explosives [i]. In addition the Environment Agency will remove the requirement for public consultation to take place before these types of waste are allowed to be burnt in the kilns, giving people less say in the amount of hazardous waste being burned in their local community.

The move comes only weeks before the enforcement of the Landfill Directive (July 16^th) which will leave the UK with only 12 landfill sites capable of processing hazardous. With the nation's industries producing a staggering 5.2 million tonnes of hazardous waste every year, the cement firms are well placed to benefit.

The cement industry has said that it wants to raise its use of alternative fuels (chemical waste, tyres, packaging waste, waste oils, animal waste and sewage sludge) from 150,000 tonnes per annum in 2001 to 1,515,000 tonnes/annum in 3-5 years time [ii]. If this happens it will have major implications for the waste industry, reuse and recycling. A full examination of whether this is the best way to utilize these waste resources needs to be conducted. The cement industry exists to make cement; it has no incentive to utilize waste in the most environmentally effective manner. It is simply burning waste, some of it classed as hazardous, to save money.

Proposed changes to the Substitute Fuels Protocol (SFP)

Since 1997, the activities of the cement industry have been directed by the Substitute Fuels Protocol (SFP). But the Environment Agency is now proposing radical changes to the system that allows kilns to burn a range of waste. These include:

a) Broadening the range of substitute fuels that can be incinerated.

At present the cement industry is prohibited from burning waste derived from the production of pharmaceuticals, pesticides, biocides and explosives. This restriction will be removed.

b) Reducing the requirement for public consultation.

The (SFP) directs that all applications to use substitute fuels be regarded as a "substantial change". The Environment Agency wants to end of this practice. This will lead to applications being determined without public consultation.

Why modify the SFP?

The Environment Agency proposes to modify its policy on the use of wastes as substitute fuels in cement and line kilns in order to "reduce the environmental impact of kiln operations" and "increase the recovery of a wider range of wastes".

However, the proposed changes threaten to undermine both of these goals. Firstly there is scant evidence that the burning of substitute fuels decreases the environmental damage caused by cement kilns. The Environment Agency argues that by including tyres and/or hazardous waste in their fuel mix, cement kilns use less coal which will reduce climate-changing carbon dioxide emissions. This may be true, but emissions of other substances such as hydrochloric acid, sulphur dioxide, cadmium, mercury, nickel, benzene, dioxins, PAHs may increase. The Agency has not demonstrated that the gains made by reducing carbon dioxide emissions offset the increased hazards from the other emissions. The Agency state in the consultation document:

"4.23 The Environment Agency considers in the light of `accumulated data' on the use of substitute fuels, that in most cases…. the request to use a substitute fuel for the first time or as an additional fuel does not warrant the automatic status of "substantial change" as the proposals are not likely to entail significant negative effects for human beings or the environment."

The accumulated data however is not included in the consultation document. Friends of the Earth has asked to see it, but was told that it is on the public register - but a person would need to visit different regional Agency offices to access the data. As they have not provided us with the data in the consultation document we have not been able to verify the above statement.

Secondly the Agency wants to achieve a greater recovery from waste. In its view this is gained by increased incineration. However, Cleanaway, one of the largest waste management companies in the UK have argued that "many of the solvent and oily wastes currently being blended into `fuels' would previously have been recycled by solvent or oil recovery operations and either re-used for their original purpose or as thinners, gun-wash or low grade oils" [iii}. They conclude, "In terms of environmental impact, simply recovering their heat content is a less efficient environmental option for these wastes as they are removed from the cycle of utility and further non-renewable resources and energy are required to replace the materials."

The Government's own goals for hazardous waste

The Government's own policy on hazardous waste is outlined in `Waste Strategy 2000: England and Wales'. It states that "reducing the amount of hazardous waste produced is a key waste management priority. By preventing waste from being generated in the first place, environmental burdens associated with resource consumption and waste treatment and disposal are avoided...". But the Environment Agency's own figures show that hazardous waste production is on the increase. The loosening of regulations governing the incineration of hazardous waste in cement kilns can only add to the problem.