Clinical Waste Incineration – is there a future?

The Waste Incineration Directive 2000/76/EC will impose strict new standards on air emissions, ash quality and monitoring. Whilst full implementation is not until 2006, it is unlikely that any incineration plant currently in use will meet the new requirements without substantial investment. That investment programme would need to start in the next year or so for the deadlines to be met, and in many instances it may be that operators will not be able to modify the plant or make available the capital to operate beyond 2005. Early indications are that none of the existing NHS plants would invest in the upgrade and private sector capacity will also close. There may be serious implications for the NHS either due to a lack of disposal capacity or in cost increases required to meet the investment needs.

Whilst continuing tightening of standards is a part of life in the environmental sector, the rationale of some of the latest changes must be questioned when considering the overall environmental impact. Lime is used in the cleaning of combustion gases before emission to air, and calculations show that in order to reduce air emissions of Hydrogen Chloride (produced by the destruction of chlorinated plastics eg PVC) by 1 tonne it will be necessary to quarry, transport and dispose of 240 tonnes of lime to landfill. How can this be right when it is considered that previous high emission standards have all been modelled and shown to have absolutely no material effect on the surrounding environment?

Industry meetings with DEFRA and the advisory group in the EA have not given any hope of anything other than a rigid implementation that will in itself present significant problems for the industry and the NHS. Having said that, there have been a number of recent examples in which legislation has not finally been implemented in the manner that it was presented by Government right up until the eleventh hour and beyond. The SMDSA has worked with regulatory bodies over a number of years in an effort to pass on its expertise when trying to match practical solutions to theoretical requirements - often little or no account is taken of this resource and we can only hope this is not going to be another of those occasions.