Following a distinct lull over the issue of end-of-life (ELV) vehicles (hazardous waste), there is now expected to be positive action to follow, presumably in the early part of next year, whereby a clear direction on all aspects of the issue will be set down by the Environment Agency (EA) for England and Wales. For those of you in other parts of the UK, you will be able to obtain advice and guidance from SEPA in Scotland and the Northern Ireland Environment Agency (NIEA).

 

This assumption follows the release of a draft document that calls for interested parties to take part in a form of a consultation, although not headed as a consultation document.

 

Within the draft document the EA provide details of their approach to the controversial issue, an issue that has been seriously questioned by AVRO, ACPO and the ABI over a number of years. Whether the concerns of the three organisations have been addressed in the draft document were not clear at the time of going to press, however the EA approach is understood to be as follows.

 

A vehicle recovered from the highway or other land by a Vehicle Recovery Operator (VRO) following a breakdown, accident, theft or abandonment will not be regarded as waste prior to its delivery to the VRO’s site or initial destination. This will be the case unless the owner of the vehicle or someone who has lawfully taken over the rights of the owner (such as the police or local authorities acting under statutory powers) has previously made a decision to discard the vehicle i.e. to have the vehicle depolluted and scrapped.

 

In the vast majority of cases, vehicles removed from the highway will not have been discarded and so will not be waste at the time they are collected. They can be moved from the highway to the VRO’s site or to another site without a hazardous waste consignment note being required. The receiving site will not require an environmental permit to receive such vehicles because they will not be waste at the time they are received.

 

If the recovered vehicle is burnt out or likely to leak fluids, it should be stored in a manner that will not cause pollution.

 

If a decision is made to discard any vehicle while it is at the VRO’s site, that vehicle must be stored on an impermeable surface with appropriate drainage and must not be dismantled at any site that does not have an appropriate environmental permit.

 

The EA then go on to explain a number of scenario’s that is hoped to better explain when a vehicle is an ELV and the controls that apply to the storage, movement and treatment of vehicles in various situations.

 

If you are an independent VRO and wish to know more, you should contact your representative association or if an AVRO member you should contact your regional council member. The EA are expecting to receive any feedback prior to mid November.