I would exercise some caution here and consult with the EA at the earliest opportunity. The EA recently had a case which was detailed in ENDS regarding use of tyres although these were whole and bound together rather than shredded at a number of riding schools. However the EA may be quite sensitive and strict in their interpretation so would strongly recommend you chat with the EA in order to determine whether they are happy.
Brad Balmer, BSc(Hons), FRSC
Associate Director, Land & Development
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-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Karen Jackson
Sent: 04 March 2014 12:37
To: [log in to unmask]
Subject: Re: Waste or not waste?
Hi Alex,
The easiest way in my opinion is for the receiver of the material to register the U8 exemption that allows the use of shredded or granulated rubber and end-of-life tyres in horse manèges (1,000 tonnes max). See exemption rules attached. Then the producer would complete a waste transfer note to transfer to the receiving exempt site.
We do lots of similar things when transferring lock gates to others who can reuse them under other exemptions.
Karen Jackson
Senior Environmental Scientist
North West, Manchester and Pennine & North Wales and Borders Waterways M. 07917 185840 Canal & River Trust, Red Bull Depot, Congleton Road South, Church Lawton, Stoke, ST7 3AP Please visit our website to find out more about the Canal & River Trust and download our ‘Shaping our Future document' on the About Us page / Ewch i http://www.canalrivertrust.org.uk/cymraeg i ddysgu mwy am Glandŵr Cymru ac i lawrlwytho ein dogfen ‘Llunio ein Dyfodol' ar y dudalen Amdanom ni.
-----Original Message-----
From: Contaminated Land Management Discussion List [mailto:[log in to unmask]] On Behalf Of Alex Bewick
Sent: 04 March 2014 12:04
To: [log in to unmask]
Subject: Waste or not waste?
Dear all,
We have had a slightly unusual problem put to us by a client. They are redeveloping a riding school which currently has an area surfaced with rubber chippings made of shredded tyres. Another riding school is happy to purchase these materials from them but the client wants to make sure they are doing everything correctly in terms of any testing or classification that may be required.
Although I think you could certainly argue that this material would constitute waste as they are removing it as part of redevelopment works, surely you could also argue that the material could be sold off as it is anyway and therefore doesn't fall into the definition of waste as it is not being discarded?
If it is waste then I'm also struggling to think how this could fit into an MMP situation as it would surely be quite difficult to demonstrate a requirement for these materials at the accepting site, demonstrating that shredded tyres don't pose any kind of risk is going to need some careful risk assessment, and I'm not even sure what you would end up testing the materials for, or even if it's possible to test shredded tyres in this way?
This is further complicated by the fact that tyres can't be landfilled any more so presumably if it is waste, it would have to go to some form of recycling centre which, presumably, could then simply sell the material back to another site that required some new rubber chipping surfacing?
I'd very much appreciate any thoughts any of you have on this matter.
Alex Bewick
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