excelar ltd UK Waste Tyre Management Best Practice: Handling of Post-Consumer Tyres Collection & Storage Anne & Russ Evans Published by: Tyres Report

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1 Creating markets for recycled resources UK Waste Tyre Management Best Practice: Handling of Post-Consumer Tyres Collection & Storage Tyres Report Project code: TYR Date of commencement of research: 15 October 2006 Finish date: 22 February 2006 Written by: Anne & Russ Evans With the assistance of: excelar ltd Published by: The Waste & Resources Action Programme The Old Academy, 21 Horse Fair, Banbury, Oxon OX16 0AH Tel: Fax: WRAP Business Helpline: Freephone: May 2006

2 UK WASTE TYRE MANAGEMENT BEST PRACTICE Handling of Post Consumer Tyres - Collection and Storage 1. Summary The UK waste tyre management industry has taken great strides in recent years to develop its professionalism and compliance with safety and environmental legislation. European environmental legislation of recent years has resulted in major changes in how the UK waste management industry operates, particularly in terms of landfilling. One aspect of this will be the total banning of tyres even in shredded form from landfills from 1 July Whole tyres were banned in July Though many waste tyre management companies have used various methods higher in the waste hierarchy for years to reuse, recover or recycle waste tyres [see Waste Tyre Hierarchy chart below], these methods are inevitably more expensive than landfill disposal. Recycling processes were ordered from the least processing required (top) to the most required (bottom) due to energy consumed in processing. Chart by EER Limited. Handling of Post Consumer Tyres Page 1

3 This report sets out the range of methods used to recycle tyres in the UK and how these are operated compliantly. Compliant operation for much UK legislation is achieved mainly by self regulation of organisations. This approach can and does lead to a broad range of compliance levels. The Responsible Recycler Scheme was launched by the UK Tyre Industry Council in 1999 to combat unprofessional practices in the waste tyre industry. The aim of the scheme was to improve the image of used tyre management by introducing new standards of best practice and demonstrating transparency, traceability and accountability. It is described in Section 7 below. Currently, this voluntary initiative encompasses twenty eight companies involved in waste tyre management accounting for 80% of the waste tyres arising in the UK. The companies are all subjected to an ongoing independent environmental audit programme and required to provide validated statistics every six months to demonstrate how they have managed their waste tyre input and output. The Environment Agency recommends the use of organisations involved in the scheme to generators of waste tyres (tyre retailers). 2. Definition of Waste Tyres The starting point for compliant management of tyre waste and one of the issues that has challenged the waste tyre industry until recently has been the definition of when a tyre is waste. This is particularly called into question in a situation where tyres are going to be retreaded or they are going to be sold on as part worn. In October 2003 the Environment Council issued a paper resulting from an industry working group (including the Environment Agency) entitled: Definition of Waste as Applied to Tyres. Put simply, a tyre is not waste if when it has been removed it is set aside to be refitted to a wheel immediately. Hence, almost all garages which remove worn tyres and collect them together, which is the industry norm, are causing all of the removed tyres to become waste, regardless of what is done with the tyres later because the immediacy requirement is violated. 3. Legislation Waste tyres are controlled waste hence are subject to the environmental regulations on Duty of Care, Registration of Carriers and Licensing of Waste Management operations. The relevant regulations being:- The Environmental Protection (Duty of Care) Regulations 1991 The Control of Pollution (Amendment) Act 1989 The Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991 (as amended) The Waste Management Licensing Regulations 1994 (as amended) In addition, some of the more technically complex methods of dealing with waste tyres such as retreading or use as cement kiln fuel require a permit to operate under the Pollution Prevention and Control Regulations. The Permit normally applies to the whole site operation with the management of waste tyres being a relatively minor consideration of the permit. Handling of Post Consumer Tyres Page 2

4 Waste tyres are not considered to be hazardous waste; however, they could be if they were contaminated with oil. In general, the main contaminants found on/in waste tyres are water and mud. 4. Compliant Waste Tyre Operations The individual pieces of legislation mentioned above are interlinked. The legislation allows different methods of compliance, and recognises the wide range of collection and recycling options. Collected waste tyres are normally taken to a site where waste tyres are sorted, after which some are treated on site if equipment is available, e.g. shredding, or used on site in retreading. Others are sent offsite to other outlets such as for export, part worn sales, crumbing/granulating, etc. For all of these possibilities, essentially the same rules apply to the transportation from producer to transfer site and from transfer site to next/end destination and so on. 5. Duty of Care Collections of waste tyres from generators such as garages should be made only by organisations who are registered Waste Carriers. The registration process is simple and inexpensive, costing 136 for three years which then can be renewed for a further three years for 96. It is recommended that waste tyre managers also register as brokers so that they can arrange for the collection and recycling of waste tyres without actually carrying out any part of the operation. There is no additional cost to register as a broker. Carriers/brokers are listed on the Environment Agency s website Public Registers and Freedom of Information section. All collections must be documented and recorded on a Controlled Waste Transfer note which is essentially an agreement between the waste producer and the receiving site. There is no standard format for the note but it must contain all relevant information about the parties who are producing, transporting and receiving the waste, such as amount, description, European Waste Catalogue code, addresses, carriers number, and recipient s waste management licence number. It is normal for a note to be made out for each collection but an annual note can be made with both producer and recipient keeping a copy and each transfer being recorded separately in addition, for example by means of a weight ticket or collection note. Waste tyre generators can transport their own waste without being registered carriers but still need to use Controlled Waste Transfer Notes. The waste generator is responsible for ensuring that their waste is transferred to suitably authorised persons such as a registered waste carriers and licensed or exempt waste sites. Each party involved must keep copies of Controlled Waste Transfer Notes for at least two years. Once the waste tyres are at the waste management site, the waste management site must exercise the same Duty of Care procedures on waste tyres that are sent offsite. Handling of Post Consumer Tyres Page 3

5 6. Waste Management Site Operations There are a number of different types of Waste Tyre Management sites. Most sites are licenced as Non-Hazardous Transfer Stations. However, where some form of mechanical treatment takes place such as shredding, sites are licenced to Transfer and Treat. Some sites are not licenced and instead have an exemption; others have a Pollution Prevention and Control Permit. The type of authorisation to accept waste will stipulate the amount of tyres allowed, usually per day or per year, and a total amount allowed on site at any time. In most cases, different types of tyres such as lorry, car and 4x4, are not specified within the permitted amounts. 6.1 Sites with Waste Management Licences Licensing of these in current years has required a good level of infrastructure with security to prevent intruders, impermeable flooring to storage areas and sealed drainage systems to prevent pollution, particularly in the event of a fire. The site must be managed by a person with an appropriate Certificate of Technical Competence. However, sites that were licensed prior to the 1994 Waste Management Licensing Regulations have not had requirements placed upon them by the Environment Agency to provide site containment. In addition, these sites are often managed by a person with Grandfather Rights in terms of competence; hence no formal qualification has been obtained. The Environment Agency monitors licensed sites through routine visits approximately monthly on average. The visits observe site operations and records to check compliance with the conditions stipulated in the license and that the site operator is working in accordance with their agreed working plan. In addition, the site management must provide the Environment Agency with periodic waste returns identifying how much waste has been received and where it has gone to. The costs of holding a Waste Management Licence vary with the site s throughput, but as an example, a small operation with a throughput between 5,000 and 25,000 tonnes per year would require an application fee of 3,656 with annual subsistence charges of 1, Exempt Sites Some sites operate under an Exemption from the Waste Management Licensing Regulations, meaning that they are authorised to accept waste but do not need a Waste Management Licence as outlined above. The operations which are exempt are listed under Schedule 3 to the Regulations and were amended in Exemptions for waste tyre operations are prevalent due to the fact that there are two listings for recycling operations involving rubber or tyres: paragraphs 14 and 17 and there is no application or subsistence fee payable to the Environment Agency for these exemptions. The criteria for operating under an exemption are strict and monitored by the Environment Agency which carries out an annual renewal visit. The onus is placed on the operator to identify that operations have changed since the granting of an exemption such that a Waste Management Licence may now be required. Handling of Post Consumer Tyres Page 4

6 Paragraph 14 states:- (1) The manufacture of finished goods from any of the following kinds of waste, namely waste metal, plastic, glass, ceramics, rubber, textiles, wood, paper or cardboard. (2) The storage of any such waste intended to be used in reliance upon the exemption conferred by sub-paragraph (1) above if (a) the waste is stored at the place of manufacture; and (b) the total amount of any particular kind of waste stored at that place at any time does not exceed 15,000 tonnes. So, apparently under Paragraph 14 an exemption exists for sites on which waste tyres are processed into finished goods if the quantity of waste tyres stored on site at any one time does not exceed 15,000 tonnes. Paragraph 17 states:- (1) The storage in a secure place on any premises of waste of a kind described in Table 4 ( Tyres are identified in Table 4) below if (a) the total quantity of that kind of waste stored on those premises at any time does not exceed the quantity specified in that Table (the Table limited Tyres to a quantity of 1,000); (b) the waste is to be reused, or used for the purposes of (i) an activity described in paragraph 11 (neither Tyres nor rubber is included in paragraph 11); or (ii) any other recovery operation; (c) each kind of waste listed in the Table (which includes Tyres ) stored on the premises is kept separately; and (d) no waste is stored on the premises for longer than twelve months. So, apparently under Paragraph 17 an exemption exists for sites on which 1,000 or fewer tyres are being stored may process the tyres in a recovery operation. Exemptions can only be granted if there is no risk to the environment; however, the information required to demonstrate this has become more onerous in the last couple of years. 6.3 Pollution Prevention and Control ( PPC ) Sites Sites carrying out a Prescribed Process such as retreaders or cement kilns operate the process under a Pollution Prevention and Control Permit. Such permits focus on the overall environmental impacts of the site with the input of waste tyres often being almost incidental. The operators are required to demonstrate that the operation protects the environment by utilizing the Best Available Techniques and these sites are extremely tightly regulated by the Environment Agency or the Local Authority for smaller operations. Hence infrastructure, site containment and security issues are very well controlled. Handling of Post Consumer Tyres Page 5

7 7. Transparency, Traceability and Accountability: The Responsible Recycler Scheme Regardless of the complexity or licensing of the business, all members of the Responsible Recycler Scheme must operate suitable robust administrative systems to be able to account for all of the tyres that they have collected, received and dispatched. The Responsible Recycler Scheme requires its members to demonstrate a high level of compliance with the legislation. This is not always straightforward as sometimes tyres are counted into sites, but once sorted they may be loaded into a vehicle and weighed. These issues are dealt with by having measured factors for each type of tyre in terms of tyres per tonne. Other processes demonstrate excellent accounting such as retreaders of truck tyres who can show audit trails with each tyre having its own individual serial number. The Responsible Recycler Scheme requires members to provide bi-annual statistics indicating the weight and type of waste tyres collected and their fates. Each member is required to validate the information it supplies by a random audit of its figures. The information collected allows the members of the scheme to demonstrate that their tyres are being handled correctly and the fate of each tyre is accounted for. The end result is a sector of the waste and resource management industry involved in the sustainable recycling of waste tyres, which is compliant with legislation and able to clearly account for all material inputs and outputs. The Responsible Recyclers Scheme requires the payment of an annual membership fee, plus the payment of an audit fee based on the annual tonnage of waste tyres handled by the member. These two fees change every year depending upon the needs of the Scheme to be self-financing. Also, scheme participants are required to be members of the Tyre Recovery Association. Handling of Post Consumer Tyres Page 6

8 Certificate of Compliance awarded by the Tyre Industry Council & the Tyre Recovery Association after an independent auditor confirms statistical compliance. 8. Storage Guidelines to Prevent Fire Note: The UK does not have formal fire prevention rules for sites on which waste tyres are being stored or processed. While local Planning Consents and permits from the Environment Agency may contain requirements for site management and fire prevention, all of which should be strictly observed, common sense dictates that all sites, even those without such requirements in their consents or permits, should adopt strict policies and procedures to prevent fires. In the USA such requirements exist in many States, and increasingly, insurance companies providing property, casualty and liability cover require adoption of Handling of Post Consumer Tyres Page 7

9 comprehensive plans done in conjunction with local fire officials. The Environment Agency s End-of-Life Vehicle (ELV) Directive contains three paragraphs on the appropriate storage of for used tyres: The ELV Directive requires: appropriate storage for used tyres, including the prevention of fire hazards and excessive stockpiling. Tyres will need to be stored so that the risk of fire or spread is minimised. Unnecessary stockpiling of tyres should be avoided. Generally, no more than 2 vehicle loads of tyres should be stored. The local fire service may have its own requirements for the storage of tyres and should be consulted by the operator. The following storage and fire prevention guidelines were assembled from various state agencies, based on the experience of EER Limited in acting as an Expert in several lawsuits against insurance companies after fires at tyre processing facilities. 1) Access to any waste tyre site should be controlled through the use of fences, gates, natural barriers or other means. California s standards specify that piles need to be 50 ft (15.2m) from the perimeter fence, and be at least 10 ft (3m) from any property boundary. 2) Almost all tyre processing operations generate heat. Processed material can exit the processing equipment at temperatures over 100 O C (over 212 O F). Material should be monitored for temperature prior to storage. 3) Stored shredded tyres with metal content should be continually monitored for heat build up due to oxidation of the metal which generates enough heat to start fires. 4) Whole or shredded waste tyre storage piles should have no greater dimensions than 8 metres wide and 15 metres long. The height of shredded material should be less than 4 metres. California s standards set maximum pile areas at 5,000 sq ft (465 sm) and total pile volume at 50,000 cf (1,416 m 3 ). 5) Storage should be clear in all directions from roof structures and any other combustible materials. 6) The width of main aisles between piles should be not less than 6 metres and should be completely clear of any tyre material. Shredded tyre material between piles will serve as a fire link between piles if a fire should occur. California s standards require interior fire breaks of 60ft (18.3m). 7) Access areas and setbacks between tyre materials and boundaries should be free of vegetation; tyres and tyre materials should not be stored on/in ravines, canyons, caves, steeply graded slopes, or areas prone to flooding, or in swamps, marshes or fens. 8) The waste tyre recycler should have a fire protection and suppression plan in place, done in conjunction with local fire authorities. Handling of Post Consumer Tyres Page 8

10 A paperback booklet might be helpful: Fire Safety for Tyre Sites. Great Britain Home Office, Great Britain Scottish Office This guide makes recommendations for safe storage of used rubber tires on sites in the open air. It describes arrangements for both new storage sites and existing sites. 69 pp. A helpful document is Guidelines for the Prevention and Management of Scrap Tire Fires published by the USA-based Scrap Tire Management Council and available at Another helpful document on waste tyre storage is published by the New Zealand government and can be obtained at 9. For additional information :- Tyre Recovery Association Tel: +44 (0) info@tyrerecovery,org.uk Important Warning The information set out in the above is of a general nature only and not intended to be relied upon in specific cases. The information does not take account of environmental issues which should be discussed as a matter of routine with the regulatory authorities (the Environment Agency in England and Wales, the Scottish Environment Protection Agency in Scotland and the Department of the Environment in Northern Ireland). Consequently, the information contained in this website is provided only on the condition that WRAP and their sub-contractors will not be liable for any loss, expense or damage arising from the use or application of such information. Individuals and organisations proposing to utilise any of the practices and methodologies within these publications are advised to seek appropriate expert professional advice in respect to their specific situation and requirements. Any errors or omissions contained within the reports are the responsibility of the respective authors. Handling of Post Consumer Tyres Page 9