The wartime adage ‘Keep calm and carry on’ seems very appropriate when speaking to Howard Bluck, technical director of the British Metals Recycling Association, especially when he is asked what have been the highlights of 2016 for the organisation.
“There has been a lot of unexpected changes – especially with regard to Brexit – but since we represent a broad church in the Association, there is a breadth of views; as far as we’re concerned, it is business as usual,” states Bluck firmly. “We are continuing to work closely with our European counterparts.”
This is demonstrated by Susie Burrage, appointed president of the BMRA in June 2016, being chosen as the new president of EUROMETREC, the European Recycling Industries’ Confederation (EuRIC)’s non-ferrous metals recycling and trading branch; and Robert Fell, BMRA’s chief executive, who has been appointed vice-president of the ferrous metals branch of EuRIC.
“Regardless of what Brexit throws up, we are committed to Europe and I view the relationship with our European counterparts as being critical as we divorce ourselves from Europe,” continues the technical director. “We need to have a strong voice as it may be our only opportunity to influence European legislation that will have an effect on our members as well as fostering international links. A lot of legislation may emanate from the UN and other international bodies and we need to make sure we’re not isolating ourselves.”
Putting Europe to one side, Bluck turns to domestic challenges that cropped up in 2016.
“There is the ongoing need to strike the right balance between legislation to protect the environment and the need to support the sector and foster innovation; we need to think about how to achieve that through risk-based proportionate legislation,” he opines before adding: “In the past, legislation has increased costs without increasing environmental benefits.”
In a sector where material prices play a crucial role in determining whether businesses flourish or perish, the technical director warns of how skittish material prices, squeezed margins and over-regulation could result in “life in the metals recycling sector becoming ‘death by a thousand cuts’”.
Along with regulation there is of course the role played by standards.
Bluck again: “We welcome the role of standards and how these can improve the quality of recyclate, which raises the bar, but we also have to be mindful the bar is not set at an artificially high level for existing operators to achieve that standard. There is a danger that a standard can become over-ambitious and affect the capacity of the UK to process the volume of materials that we generate.”
Other issues that the BMRA will continue to tackle on behalf of its members in 2017 include the fire prevention plans first published by the Environment Agency in July 2016.
“Broadly, we welcome the approach and it’s got the industry talking and taking fire risk and management seriously. However, the guidance has thrown up two issues: namely, separation distances between piles of materials and a site’s boundary as well as the physical size of these piles,” explains Bluck. “The fire prevention plans state six metres are needed between piles of inflammable waste. This is particularly challenging for BMRA members where space is constrained, especially for those in urban locations where historically housing wasn’t located nearby. For some, the amount of materials is being seriously reduced and we are having conversations as to whether the sites are fit for purpose.”
According to Bluck, while some BMRA members can move their premises, others may have to work with a reduced volume of materials or turn materials away, which has risks for the operation and the environment. “We are in dialogue with the EA about whether a sector-specific approach to fire prevention plans could be developed,” he states.
Whether it concerns European bodies such as EuRIC or governmental organisations like the Environment Agency, the theme that crops up continuously in the conversation with the BMRA’s technical director is collaboration and dialogue.
“I spend a lot of time on various committees looking at issues such as WEEE treatment standards. The WEEE work is pretty much coming to a conclusion, but there will be discussions at EU level on other end-of-life product treatment standards, along with considerable work on the European Ecodesign Directive for enabling more efficient dismantling of products,” continues Bluck, before expressing frustration with the absence of progress made over the Circular Economy Package.
“Much has been said about it and there is a real disappointment over the lack of pull mechanisms to encourage people to use more recycled content,” laments the technical director. “This is something we are focusing on to encourage last users to ensure their goods are sent to legitimate facilities where they will be recycled to the highest possible standard, and to encourage the manufacturers of new products to use recycled content for all the environmental and social benefit. One of the challenges for 2017 is how to effectively market recycled metals that have a lot of green credentials in terms of reduced energy demand.”
He points to plastics where, due to lower oil prices, material reprocessors have to compete with cheaper virgin products. “We have had meetings with the Commission as to how we can stimulate interest.”
But of course it is not all about challenges and sombre outlooks. Bluck flags up steelworks specialist Liberty House, which is resuming production of steel structural hollow sections at its plant in Tredegar, Blaenau Gwent, and investing £3.7m in updating the facility, backed by £600,000 from the Welsh government.
“There has been a lot of talk around ‘green steel’ and what’s going on with Liberty,” comments Bluck. “It’s a very topical issue with plenty of political interest in the steel manufacturing sector and how secondary raw materials can be put to the forefront.”
There is also cautious optimism over the Air Weapons and Licensing (Scotland) Act 2015, which was introduced on 1 September 2016 and which brought in stricter licensing and ID requirements, as well as a cash ban for recycled metal transactions in Scotland.
“In terms of the implementation, most of our members have been visited by the police to check that everything is right and proper. We are aware that some yards have come under scrutiny, mostly concerning issues over licensing. One of the advantages for Scottish merchants is they were able to see what happened with the Scrap Metal Dealers Act in England and Wales, so it came as no great surprise to them to the way they kept records and they are required to make payments,” explains the technical director, before going on to add a note of caution.
“There are a couple of missed opportunities. For instance, it is a shame that despite our lobbying to the Scottish government for both sides of the transaction to be ‘cashless’, it is an offence for a metal dealer to pay cash to the customer, but not an offence for the customer to receive cash. This means there is an opportunity for less scrupulous dealers to make payments that are ‘agreeable to the customer’.”
Two other concerns are the perceived lack of commitment over drawing up a national register of itinerant metal dealers. “We are waiting for secondary legislation to be drafted,” says Bluck. “This means it’s harder for the police to know who is licensed and who is not.”
And the other thing that is weighing on the BMRA’s mind is enforcement of the regime when police funding runs out. “They have money to enforce requirements, but will there be dedicated funding going beyond April of next year? If there is no allocated funding, we may see cash returning to the system,”warns the technical director.
Speaking of enforcement, the technical director refers to the continuing ‘troubled’ relationship between the BMRA’s members and the regulators.
“We are seeing regulators focus on the compliant operator so very often they are seen as an easy target. As they are broadly compliant, but might have a crack in the concrete, they get berated for that, even though around the corner an illegal operator doesn’t play by the rules and can operate a business with impunity. We are very keen this is addressed,” emphasises Bluck.
In a world of increasingly limited resources and manpower, the BMRA’s technical director sees collaboration as the way forward in the war against illegal operators.
“We are beginning to see multi-agency days of action with organisations such as the HSE and the EA. Collectively they have the knowledge and experience, and we should welcome this as it helps their limited resources go further. Illegal operators are a blight, and without robust enforcement we are not going to see them disappear.”
For more details, visit www.recyclemetals.org