Waste to Oils
SOURCE: CIWM, SEPTEMBER 2008
It is now just over a year since the OSS case confirmed that fuel manufactured from waste lubricating oils could be fully recovered, such that it could be burnt as a non-waste product, if it comprised a distinct marketable product that could be used in exactly the same way as an ordinary fuel, and with no worse environmental effects. The legal test has therefore been laid down and the challenge is now to apply it properly in practice. Full responsibility for doing so now lies with Defra and particularly the Environment Agency.
The Quality Protocol (QP) for producing processed fuel oil from waste lubricating oils, issued for consultation at the end of July, is the opening step in this process of applying the legal criteria in practice. An intense period of consultation will now ensue – its primary object being to ensure that the final QP faithfully applies the legal test laid down by the Court of Appeal.
It is acknowledged that this is no simple matter. There will inevitably be tensions and differences of opinion as to the extent to which this is achieved or not. What is important is that all stakeholders bear in mind that the QP is supposed to be the technical implementation of the legal test, but it is not the legal test as such.
Nonetheless, the very fact that there is now a clear and authoritative legal judgement, supplemented by a draft technical protocol, into which serious contributions can be made from industry, is only to be welcomed in furthering the sustainable recovery of this difficult waste stream.
AUTHOR: Vincent Brown
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