We have been seeing a roll out of the new waste management licence templates from SEPA (now called Waste Management Permit). It is good to see a change from the pages of conditions on the previous waste management licences but has this gone too far the other way?
The ones we have seen have no EWC codes for waste acceptance, just authorized activity of storage and treatment of for example non-hazardous waste – there are some exclusions but still a wide range of non-hazardous waste that can be brought into a site that only wants to accept for example construction waste. There is no reference to the process or to the working plan for the site. Can I go from processing plastics to processing construction waste without any notification to SEPA? I am still within my description of authorised activity – the keeping and treating of waste.
How does a company demonstrate to customers that they can accept a particular waste type?
Interesting times ahead to see how SEPA will enforce these licences.
Has anyone one else received these and can foresee issues in the future?