Implementation of the Materials Facility (MF) Regulations is set to pose 'significant challenges' across the whole industry, according to experts at a conference held in Bristol earlier this week (1 July).

The MRF Regulations: Implementation and Improving Value Across the Supply Chain event, organised by Resource Media and Resource Futures, saw speakers address quality and value issues of recyclate from the kerbside to the reprocessor.

The introduction of mandatory sampling for MFs will force changes to recycling communications, as well as present health and safety challenges at materials recovery facilities, attendees heard.

Short-term increases in price and long-term increases in quality

Addressing delegates, Andrew Bird, Chair of the Local Authority Recycling Advisory Committee (LARAC), warned that the regulations would have a feedback to co-mingled recycling collection systems. He said: “In the short term, this could lead to an increase in costs [for councils], though this is not necessarily a bad thing in the long run. Contamination will now be an issue, where it hasn’t in the past.”

Costs will rise when local authorities are challenged to reduce contamination, as the sampling of input materials to MFs will highlight problems, Bird said. He noted that, at a time of reduced budgets, there would be a need for more communications to householders. However, in the long run, he felt the improved focus on material quality could reduce the costs paid by councils for recycling collection.

Linda Crichton, WRAP’s Head of Resource Management, also expressed the view that MF sampling will improve collection services. Knowledge of contamination would help to inform changes and should ultimately lead to lower rejection rates.

She pointed out that the MF regulations had the potential to “demonstrate compliance with separate collection requirements – the ‘necessity’ test set out in the Waste Regulations”, but that it was equally possible “this information could make it difficult for an LA to demonstrate its existing collection scheme is compliant if it failed to demonstrate high-quality recycling”.

Health and safety concerns

One of the key issues facing materials facilities charged with implementing the regulations are the health and safety requirements posed by regular sampling. Stuart Hayward-Higham, SITA UK’s Technical Development Director, stated: “We’ve spent many years getting people out the way at our facilities to improve our safety record, and now we want them to go and sample materials. It’s quite difficult to do that as a lot of our infrastructure has been designed with people out the way and now we have to try amend them with people in so we can do the sampling.”

Based on SITA’s experience, he noted that there were shortcomings with representative sampling. He continued: “We don’t think there is anything reliably that we can conclude for at least 18-24 months after we start sampling. We should ignore for the first 12 months because there is not enough evidence to statistically [confirm that] they are accurate, and therefore only in two years’ time we should be making some decisions about collection rounds – is the configuration right, are we doing the right thing?”

Enforcing the sampling regime

Speaking on behalf of the regulator, Chris Bower of the Environment Agency said the job of his team was not to judge the quality of the material sampled, but simply to enforce that the sampling system was adhered to. He stated that the EA would be begin a programme of introductory visits to MFs in the summer, and advised facilities to engage with the process early.

He said he currently expected there to be in the region of 200 sites that were likely to be subject to the new legislative requirements, and that in the first place, the EA is aiming to make the regulation as ‘light touch’ as possible. To meet the cost of inspections, he anticipated that fees are likely to be in the region of £2,240 per site.

Sam Reeve, Operations Director for event hosts Resource Futures, noted that a good sampling system would require dedicated staff, with specialised training. He estimated that an MF processing 100,000 tonnes a year would require 60 hours per week of staff time to conduct sampling to meet the regulations.