What is TEEP and How to Comply? Was the Big Question at UK LWARB Event

There has been a tangible feeling concern developing within the UK's waste collection and handling industry this last few months. In the main, the cause has been the thinking behind a new acronym that adds to the European’s ever increasing "waste glossary". 

 The abbreviation is "TEEP", and it refers to "technically, environmentally and economically practicable" requirements of operating standards for recycling collection systems. It has emerged as an important new requirement embodied within the EU’s Revised Waste Framework Directive (rWFD) which must be adhered to by European waste collection authorities and delivered by their contractors."

 The LRS Consultancy hosted the UK LWARB Event, which was the first high-profile UK event to pick up on the new legislative requirements, and they have explained in an article in the CIWM that they were responding to requests from their clients for information on the subject. Wayne Hubbard, chief operating officer, LWARB event said about TEEP that:

"It seems there has been overwhelming tension and anxiety about TEEP with no outlet or easily accessible information to date".

The event was apparently well attended and acted as a forum for local authorities and the resource management industry to listen to keynote speakers, and discuss the future of their recycling services when they will be complying with the new legal requirements for TEEP compliance. If TEEP is to have real value in enhancing sustainability within the waste management industry in Europe it will need work in a manner which will support the circular economy. The intent is that it should do this through ensured improved material quality emanating from the member nation’s collection, transport, and waste processing/ recycling industries.

So What Exactly is TEEP?

The European Union's Revised Waste Framework Directive (rWFD) includes a requirement to set up separate collections of the following as a minimum: paper, metal, plastic and glass, from the household waste stream by 2015. Article 11 of the rWFD states that "Member states shall take measures to promote high quality recycling and, to this end, shall set up separate collections of waste where technically, environmentally and economically practicable and appropriate to meet the necessary quality standards for the relevant recycling sectors."

 At the UK LWARB Event “feathers were ruffled” to a certain extent by the fact that time to implement is by anyone’s estimation really short, and once imposed in January 2015, the regulations will be enforced by the Environment Agency. Those in charge would have to be extremely diligent in adhering to the concept of TEEP as non-compliance might possibly lead to criminal prosecution. It seems that the concern is that at this time there is a lot of work to be done to establish what will be compliant when TEEP assessments are made.

The view appears to be that the decision as to whether compliance with the rWFD requires separate collections as opposed to commingling will rest upon interpretation of the TEEP rules, and an exercise of judgement. That judgement will not be clear-cut as it will need to balance technical, economic and environmental considerations in each waste management site’s, specific circumstances.

With that in mind it is not surprising that all waste professionals involved will find it hard to rest until through industry discussions and legal advice, the TEEP requirements can be crystallized into some form of good practice guidance which the professionals involved can rely on as a fall back to support their waste collection and transport policy decisions. The LRS Consultancy Article in the January 2014 edition of the CIWM Journal gives the LRS view on the emerging industry wide opinion, as follows:

“TEEP requirements may provide many challenges for everybody along the supply chain and it is evident that there are no right or wrong answers. Indeed, there are rumors that any further definitive stance may only arise after the first legal challenge completes.”

The article suggests that Defra ministers will be giving further consideration to whether additional information or guidance is required, but the view on exactly what is needed seems to be somewhat fragmented with some local authorities wanting structured guidance and advice, while others may be of the opinion that they can decide how best to proceed on their own. LRS indicates that they will continue in their current role;

"as a catalyst to sharing knowledge and facilitating connections, and positive change enables LRS to understand the views from along the supply chain".

Meanwhile, LRS is offering their own suggested list of actions for local authority officers, and those involved in the supply chain. The first action they proposed is that Councils: "Get TEEP on to your risk register. Some councils are currently scoring this at the highest possible risk level on their register. It's appreciated, however, that new policy decisions are very unlikely ahead of elections next year."

The financial aspects of TEEP implementation will be central to the thoughts of Council officers at this time of expenditure cuts: According to the LRS, CIWM article:

"Jamie Blake, director of public realm, London Borough of Tower Hamlets said: "Local authorities find themselves having the most amount of money taken out of their budgets in recent memory. We are halfway through a six-year programme of service reductions, after which most authorities will have reduced their budgets by over 45 percent. Many authorities will find during their assessments that adding in separate glass collection, for example, will be very costly and highly disruptive to services and, therefore, clearly not economically practicable, particularly within an existing contract.""

Given the availability of initial council staff time to work through the changes TEEP implies for many, TEEP can be seen positively as a catalyst to review long-term strategies, and by improving processed waste material quality bring another step-change toward a vibrant circular economy. TEEP, when viewed with a healthy dose of optimism could also provide the push needed to end stagnating recycling rates, and capture more materials beneficially, while adding value from these materials through better quality. Whether it will, when both finances and council staff resources are as pressed in the UK as they uniquely are by the deep cut-backs in progress through 2014/15, and at such short notice of implementation, must surely be an open question.