A fair CoP? MRF sampling, testing and reporting: Big problems caused by small particles. Part 1: Compliance difficulties and data validity

The Regulations governing Materials Recovery Facilities (MRFs) in England require that they report on the quality of both the incoming mixed wastes and the single-stream recyclate products, with the results being made available on a public register. In this investigation, tests were conducted on a number of mixed wastes from different suppliers being processed at a qualifying MRF to evaluate how effective the Regulations (or MRF Code of Practice (MRF CoP)) were in generating useful, meaningful information. The empirical evidence obtained showed that MRF CoP in its current form has a number of serious flaws which detract from the validity and value of the reported operational data. The statutory definition of ‘material particles’ in the mixed wastes given in the MRF CoP means that compliance with the MRF CoP is impracticable, and in order to overcome this it will be necessary to re-word the definition of ‘material particles’. Empirical evidence also invalidated the explicit assumption made in the MRF CoP that the composition of the material particles is identical to that of the bulk materials, and consequently the basis for the mandatory apportioning of the weight of the material particles has no logical foundation and apportioning leads to distortion in the reported data. Changes will be required to the present statutory requirements for reporting operational results if the recorded information is to have meaning and relevance for stakeholders in the system.