Interesting. Sounds like re-use of a material that has already satisfied end of waste tests. Provided material is required and suitable for use at new recipient site and only quantity required is used then it looks like re-use.
Sent from my iPhone
On 4 Mar 2014, at 12:05, "Alex Bewick" <[log in to unmask]> wrote:
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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