WM3, the Environment Agency’s Waste Classification – Guidance on the classification and assessment of waste is upon us, handed down from on high as if on tablets of stone.
WM2 had an embarrassing start with wholly incorrect advice that served to demonstrate a fundamental lack of understanding and incompetent technical advice regarding clinical wastes and the potential hazards thereof.
Though the worst errors were quietly corrected without a word of acknowledgement that the WM2 guidance document had been revised, the entire debacle was a keynote example of the discord between science and those who seek to regulate.
And now we have WM3, compiled in a radically different format that seems unnecessarily cluttered, like an undergraduate essay that seeks to put in so much, as if to impress, that it becomes confused, cluttered and somewhat unhelpful. There is much that is good, some of it spoiled by over-complication. Indeed, so much of that over-complication exists, with heavy reliance of statistical assessments of waste properties that the emphasis now is on a challenge to operators to jump though sometimes unnecessary and inappropriately high hoops for no real gain.
This has been a feature of the more recent EA approach to regulation that has been seen particularly with regard to the fate of pharmaceutical residues in healthcare wastes. Operator after operator have been challenged to produce the same desktop exercise regarding the fate of drug residues. It’s as it they are required to serve a penance, since there is little scientific value to these assessments and no operational gain.
Back to WM3, the fundamental error in that section addressing the risk of infection from healthcare wastes is the line of thinking about how infection might arise and which organisms are present in and on the human body, and where they are.
We are covered with organisms, many of them potentially hazardous and capable of causing infection if they get into the wrong place in sufficient numbers. Which wastes might require special precautions to prevent infection is a meaningless point for distinction of one waste stream from another. The organisms don’t discriminate, and may cause infection whether present of some item of clinical waste from a hospitalised patient or found in a sewer pipe ready to bite an unfortunate plumber!
The line has to be drawn somewhere, yet the internal conflicts in waste classification leave open the discord that is perpetuated. EA may as well say “jump though all of the hoops we can create and if we are happy with your performance you will receive a permit. Make waves or challenge us, and you will not”. Science does not come into it at all.
Hopefully, WM3 will improve through extensive rewriting and simplification, based more on sound scientific reasoning than on EA ideology.
But don’t hold your breath.
The current Government had promised to clean up health and safety and other legislation to remove unnecessary red tape. Have they looked at the red tape, business practices, and integrity of the Environment Agency and individuals on its payroll?