The “open” question: HWRCs and COVID-19

At the time of writing, the UK is in its sixth week of ‘lockdown’, the informal term for the restrictions the government has put in place to curb the spread of COVID-19. It is hard to find any part of society that hasn’t been impacted, with waste services being no exception.

Whilst councils have largely managed to maintain their kerbside collection services, household waste recycling centres (HWRCs) have been hard hit: a recent survey found that around 94% of waste disposal authorities (WDAs) in England have closed their HWRCs temporarily. Now, the government is encouraging councils to consider how they may be able to reopen sites. In this article we consider why HWRC services are important and the various guidance that has appeared regarding how they could be operated safely.

Supply side shock

The main concerns that have been raised regarding the closure of HWRCs are the inconvenience it causes for people, and fears that it may exacerbate fly tipping. However, the effects of closing recycling centres extend beyond the immediate site users and staff, extending throughout the onward supply chain. Councils are seeing an increase in household waste presented at the kerbside, as people spend more time at home and can’t take waste to the ‘tip’. To help make the situation more manageable, the Environment Agency has relaxed rules on transfer stations to allow more material to be stored for longer.

Combined with a shortage of staff, the increase in waste initially led some councils to focus resources on collecting residual waste and recycling, and temporarily stop collecting garden waste. With HWRCs also closed, the composting industry was hit hard, although these effects should diminish, now that more than three quarters of councils have garden waste collections in place.

Meanwhile, wood feedstocks are down by approximately 90%. It has also been reported that scrap metal availability has dropped significantly, and that around 10% of energy from waste plants are not operating at normal capacity.

Another concern is how closing HWRCs, which play a key part in WDAs’ efforts to collect waste for recycling, is reducing the likelihood of meeting recycling targets. In Wales, councils have statutory targets, and failure to meet them brings financial penalties. Maintaining the health of staff and residents has to be the priority, but consideration may need to be given to the unique challenges that COVID-19 has posed for waste management this year – although the extent of the impact is not yet clear.

Open season

Now the mood music is changing to favour reopening HWRCs. This isn’t coming solely from ministers: survey data shows that 84% of WDAs now have a plan in place to reopen at least some HWRCs, although the timeframe varies:

“11% of respondents… suggested this would occur in the next week, 37%, within the next two weeks, 46% (the largest share), within the next month and 6%, in more than a month’s time.”

But can this be done safely? The government’s position on this is somewhat confusing. It states that:

“[t]here is no reason in law why HWRCs cannot be open and where possible, local authorities should seek to retain access to HWRC services for their residents to dispose of waste.”

While it also emphasises – gesturing towards the lockdown Regulations – that “[h]ouseholders should only take waste to a HWRC if it cannot be stored safely at home and no alternative disposal options are available”, it says that councils should take no steps to police this limitation:

“Staff working at HWRCs should not be expected to determine if visitors to the HWRCs:

• • are making a legitimate journey
  • are bringing items that can or cannot be stored safely at home

The police cannot assess what is or is not a legitimate trip to a HWRC, and they will be unable to assist in this respect.”

It may be possible to make it less likely that householders will have reason to visit a HWRC by making temporary changes to kerbside collections, such as relaxing side waste restrictions.

Free advice

It is clear that reopening sites within the current climate will present a new set of health and safety challenges on top of those that sites already contend with, and a number of organisations have put forward guidance on whether, and how, HWRCs could reopen.

• A recent Suez report argues that “only if residual or food waste did not have a collection regime (of whatever infrequency) would it be lawful to open an HWRC under the current Restrictions”, although it goes on to propose ways to make their operation safer.
• Guidance from local authority representative bodies suggests that a risk assessment is needed for each site that proposes to reopen and that the outcome “might determine that certain sites will not be able to restart or can only restart with modifications.”
• Meanwhile, Veolia has published guidance on how to open HWRCs to “enable visits… which are essential to prevent injury, illness or harm to residents”.
• Other guidance has been published by Defra and the Waste Industry Safety and Health Forum (WISH).

WDAs will need to digest these various sources of guidance in order to try to find a safe way of working on their sites.

Separate ways

Whilst there are some differences in content, the common overarching aim is to try to reinstate service provision whilst ensuring the protection of staff and the public – mainly by limiting the number of close interactions between people. Since the direction of travel now appears to be towards reopening, it’s worth summarising some of the main recommendations:

• Limiting the number of people visiting the site – It is important that sites do not become overwhelmed, but simply limiting the number of cars on site at any given time could give rise to long queues. Possible measures to control numbers include the use of an online booking system, although this would take time to set up; or opening for specific postcode areas on different days. It may be sensible only to allow single occupancy vehicles into the site to limit the number of people. These measures would need to be widely communicated, and pose the challenge of enforcing them at the gate. Queues onto the highway remain a risk, which will need to be managed by site staff and service managers.
• Restricting the number of containers in operation and materials accepted – the aim of such a measure is to spread the operations out across the site to facilitate social distancing. It is also consistent with the government’s suggestion that HWRCs should open only for material that cannot safely be stored at home or collected at the kerbside. However, changing the ‘norm’ in relation to the materials accepted on site would require clear communications to residents on the service available. Such restrictions may make the site easier to manage in the short-term, but could impact on recycling performance, with potentially recyclable materials being diverted to the residual stream.
• Maintaining social distancing on site – whilst both of the above measures will assist in reducing interactions between the public and site staff, maintaining a minimum of two metre separation between individuals is important to prevent the spread of COVID-19. It may also be necessary to suspend site staff assisting the public with unloading material; again, communication of this change will prevent confusion on site when the public use the service.
• Enhanced site cleaning and PPE – sites should implement more regular cleaning of ‘touch points’, such as railings and site office areas, to reduce the potential transmission of the disease. Staff may also require additional PPE, including face masks, and access to hand sanitisation points, to reduce their risk of exposure.

These measures will go some way to providing a short-term solution to allow the reopening of some HWRCs. However, uncertainty remains regarding how many people will deem it necessary to use them, and how long special arrangements will need to be in place. If we are going to be grappling with COVID-19 for many months to come, as seems likely pending the development of a vaccine, operators will need to consider investing in more substantial site changes in order to allow more sites to open safely – especially if lockdown measures are eased and the public comes to expect a return to something like business as usual.

Featured image: Alan Tennyson (CC BY-SA 4.0), via Wikimedia Commons.