| No. |
Hazard Category |
Description of Hazard |
Probability of Hazard
Occurring |
Impact of Hazard Occurring |
Factors Which Lead to
Realisation of Risk |
Contingencies/ Plan of
Action |
| 1 |
Capacity |
Non-MSW - BPEO has only addressed
MSW (~25% of total waste stream). Impact of planning for future
infrastructure considerably underestimated. |
Projected capacity is underestimated
due to lack of robust and complete data on non-msw and awaiting
the Non-MSW BPEO Plan. |
"Other wastes" are
complex and data on arisings is severely limited. Until this
is resolved then it is difficult to plan for infrastructure for
other wastes.
|
Data reporting/ collection
systems are not adequately developed to improve understanding of
other waste streams. |
Using Priority Waste Stream
Project national data at the local level to identify selected Non-MSW
streams within L&B. Await further PWSP outputs. L&B SWMBA
(1999 data) indicates that for every 1 tonne of MSW collected by
LAs, a further 1 tonne of waste was collected by the private sector
- get feedback from SESA on additional capacity requirements for
planned infrastructure. |
| 2 |
Capacity |
Sizing and projected phasing/
implementation of future capacity of infrastructure as AWP doesn't
make it sufficiently clear that projected infrastructure is for
MSW only and is likely to increase as other similar wastes will
also be processed at these facilities. |
See above for impact of "other
wastes" on MSW infrastructure. Contracts and funding not fitting
in with current projections. Planning not allow development of required
infrastructure. |
Not meet legislative requirements
- landfill directive, recycling/
recovery targets.
|
Planning Authorities restrict
development of new infrastructure at required total capacities to
accept other similar wastes as well as MSW as it is considered that
the scale of facility is not in accordance with the AWP. |
AWP to assumptions behind
sizing and phasing of facilities clearer. Ensure Planning Authorities
are on-board with sizing and projected phasing of new facilities
and take more of a proactive role. Engage planners with Waste Industry. |
| 3 |
Capacity |
Projected treatment /diversion
from landfill for L&B BPEO doesn't provide enough buffer to
comply with landfill directive in the event of technology failure. |
Up to 2010, projections are
quite robust, but situation becomes less so from 2013 onwards -
when targets become harder to meet, AWP hasn't been specific on
technologies to be undertaken (newer technologies could be more
likely to fail if not adequately tried and tested), and data projections
are harder to determine. |
Not meet legislative requirements. |
Haven't allowed for enough
of a buffer in compliance to take unforeseen failures into account.
No system to purchase permits developed. Implementation of new technologies
that could be more likely to fail if not properly tried and tested. |
Ensure decision on the development
of "other technologies" is for sound technologies. Carry
out sensitivity on compliance with Landfill Directive in L&B.
Try not to rely on having to purchase permits. |
| 4 |
Capacity |
Forward capacity of landfill
not adequately considered. |
Difficulty in getting void
space/capacity information from annual returns. |
NWS objective was to provide
forward capacity. Also need to identify need for future landfill
to be considered against future planning applications. |
Data not reported to PPC
teams, data not collected by data officers, inconsistent calculation
of forward capacity. |
First attempt at identifying
forward capacity has been undertaken but requires further work -
forward action in AWP. |
| 5 |
Cultural Change |
Failure to change current
"throw away"/"high consumption" attitudes and
behaviour to improve resource management. Main issues = low participation,
apathy/fatigue, low priority for some. |
Awareness campaigns are ignored
as a low priority, un-coordinated messages confusing the issue,
no service legislative/ economic back-up to encourage change. |
May be forced down the road
of non-sustainable technologies versus opposition to such sites,
not achieving targets in AWP. |
Lack of finance to advertise
message, low levels of knowledge = no change in behaviour, un-coordinated
message delivery. |
Development and implementation
of consistent, clear campaigns and monitor to establish impact on
behaviour changes - Waste Aware Lothian and Borders. |
| 6 |
Data |
1995 Baseline - how this
is apportioned will affect AWP and diversion rates, if Scottish
Executive don't go with 1998 arisings option. |
L&B AWP has planned diversion
requirements on projected growth rates from most up-to-date waste
arisings data (2001-2002 for final AWP). The minimal impact for
Scottish Executive allocation of the 2.8 million tonnes apportionment
is based on 1998 arisings so any other option would impact on L&B
AWP BPEO assumptions. |
Lower 1995 baselines will
not have planned for high diversion rates required.
High impact on most AWPs.
|
Scottish Executive don't
agree 1995 baseline in accordance with 1998 arisings option. |
L&B WSAG has written
to Scottish Executive requesting feedback on this issue - awaiting
response. |
| 7 |
Data |
Gaps/ uncertainties/ assumptions
in data - MSW and other wastes. |
Non-reporting of data, not
recognising future data needs, lack of resources to collect data. |
If sufficient data is not
available, unable to forward plan for future AWP implementation. |
Under resourcing of data
team, non-compliance of data providers, historical data problems. |
Waste Data Strategy set up
to collect data strategically, continued co-operation with PPC teams. |
| 8 |
Data |
Growth rate - projected growth
rate inaccurate (too low). |
Currently based on historical
data and in some cases relates to population/ household growth projections.
Whilst OK for short term, projections become less robust in the
medium/longer term. |
Insufficient capacity and
number of facilities developed. |
Demographic increases, consumption
patterns, no impact from increased public/business awareness, no
impact of legislation (e.g. packaging), inconsistent historical
data collection. |
Flexibility for future infrastructure,
monitoring, understanding and interpretation of data trends, audit
LA reporting, consistency of reporting. |
| 9 |
Data |
Composition - variances in
national composition to local/ actual composition. |
Recent analysis doesn't vary
significantly. |
Not planning for right facilities/
technologies to deal with actual waste types arising. |
Change in consumption patterns,
new packaging material developments, new legislation requiring recovery,
changes on composition of future wastes. |
Ongoing local waste analysis,
requiring standardised methodology. |
| 10 |
Funding |
Access to revenue, capital,
bankability of new technologies, financiers/ Scottish Executive. |
Current insufficient SWF,
no commitment to extend funding beyond 2004, failure of new technologies
to meet due diligence. |
Failed development of infrastructure,
non-implementation of AWP, not meet landfill directive requirements. |
SWF does not continue, SWF
is not increased to meet implementation requirements, lack of specific
criteria on allocation of SWF (guidance still in draft), lack of
confidence by private financiers. |
Clear understanding of cost
implications to implementing AWP, LA's provide more specific costings
in implementation plans, ensure investment in bankable technologies,
strategic spending (pulling together range of smaller funds and
better co-ordination of localised funds), make landfill disposal
more expensive. |
| 11 |
Landfill Directive Target
Derogation |
Failure to take up 4-year
derogation for implementation of Landfill Directive diversion of
BMW targets. |
Awaiting final decision from
Scottish Executive, Current BPEO assumes 4-year derogation will
be taken. |
Given current high reliance
on landfill disposal, bringing landfill directive targets forward
would place unrealistic timescales on any attempts to meet them. |
Lack of direction from the
Scottish Executive, lack of understanding of implications for non-compliance
if targets brought forward, planning and commissioning of infrastructure
would take too long to meet short-/medium-term targets. |
SEPA, COSLA, SESA, etc. to
encourage SE to influence national government to make a definitive
statement on the need to take up 4-year derogation. |
| 12 |
Local Government |
Local Government reorganisation |
Local Government may be subject
to statutory reorganisation but will also reorganise voluntarily.
The frequency of the latter is not possible to predict, particularly
in the longer term. |
Dependent upon when reorganisation
occurs: if key decisions are delayed with regards to meeting Landfill
Directive targets this could seriously affect the AWP, if reorganisation
changes LA boundaries, application of targets, meeting Landfill
Directive requirements will be affected. |
Steer from central government
on requirement for local government re-structuring, local political
decision for local restructuring. |
Ensure that Scottish Executive
and key local decision makers are kept fully involved in implementation
of the AWP and are made aware at the earliest possible opportunity
of re-organisation impacts. |
| 13 |
Mixed Waste Processing Facility
Outputs |
Mixed-waste-treatment facilities
producing low grade material unsuitable/unwanted by the market,
e.g. low-grade mixed-waste compost, RDF. |
Emerging mechanical and biological
waste treatments (MBT) largely unproven yet in the UK. (Port Neath,
Wales - plant due to start operations by end of Aug 2002), uncertainty
over compost standards. |
Proposed contribution of Mixed
Waste Processes to meeting landfill directive diversion will fail,
may result in increased requirement for EfW. |
Product specification/quality
not fit for purpose or meet regulatory standards. Processes may
take time to develop necessary expertise and segregation to produce
higher quality outputs. |
Monitor good practice of
similar technologies across Europe and UK as they become established.
Begin establishing effective front-end waste sorting treatments,
provision of realistic and operational standards guidance, effective
regulation. |
| 14 |
New Technologies |
Failure of new technologies |
L&B BPEO is looking at
potential of new treatments/ technologies to process MSW and meet
recovery targets. |
If new technologies do not
perform as expected this may result in increased reliance on low
waste hierarchy treatment options. |
Inability of new technologies
to deal with MSW waste stream, accidents and risk averse financiers. |
More source segregated collections
in place less reliance on treatments that have to process mixed-waste
streams. Need for independent research into the effectiveness of
new technologies. |
| 15 |
Non-BPEO Proposals |
Development of Non-BPEO facilities |
Although the AWP is a material
consideration for the planning system and SEPA is a statutory consultee,
the planning system will have the final say on whether or not a
facility is built. |
Non-BPEO facilities have the
potential to significantly alter the BPEO for the area. |
Non-statutory nature of AWPs.
Lack of awareness of local planning decision makers of the BPEO,
no consideration of PAN63 or NPPG 10, local public pressure to make
a Non-BPEO compliant decision. |
AWP's to be as clear as possible
on what the BPEO is, to avoid misinterpretation, SE to call in applications
which are contrary to AWP in a consistent manner, local decision
makers to take responsibility of making some locally difficult decisions
and not bow down to locally ill-informed pressure. |
| 16 |
Partnership Working |
Lack of strategic co-ordination
between the agencies with a role to play in implementing the Area
Waste Plan. |
Agencies have individual
targets and objectives which can lead to a non-strategic approach
to environmental and related issues. |
The Area Waste Plan cannot
be implemented without the participation and partnership working
of other agencies/ stakeholders. |
Continued gaps in joined-up
thinking, waste not considered a key issue for a stakeholder agency
to resource. |
Scottish Executive need to
establish waste clearly on performance measuring requirements of
public sector agencies, e.g. Scottish Enterprise networks, etc.,
clear allocation of AWP implementation responsibilities to all stakeholders,
raise awareness of responsibilities to key decision makers and importance
of AWP implementation. |
| 17 |
Partnership Working |
Joint tenders and contracts
cannot be awarded to facilitate joint development of facilities
between LA's and WSA's where this presents better economies of scale. |
Joint tenders between Local
Authorities have never been undertaken previously. |
Lose the WSA momentum of building
partnerships over the last 2 years, LA's just concerned with meeting
own targets and not think strategically, lose out on potential economic
benefits of combined facilities and joint working, LA's have a reduced
negotiating power by working alone. |
Restrictive public procurement
mechanisms, lack of clear joint tendering guidance from Scottish
Executive finance, LA's working to different implementation timescales,
uncertainty of joint working options available. |
Scottish Executive need to
develop clear partnership working mechanisms for the Public Sector
Procurement. |
| 18 |
Planning |
Land use requirements of
Area Waste Plans not identified by the planning system. |
Historically the planning
system has not identified land suitable for the development of waste
management facilities, politically sensitive for planning authorities
to undertake. |
If suitable sites cannot be
identified then facilities will not be built in time to meet landfill
directive diversion and other targets. |
Planning Authorities do not
take the AWP into account when preparing local plans and do not
follow NPPG 10, PAN 63 guidance. Planning authorities can't meet
resource requirements to undertaken future land-use requirements
for waste. |
Engage Planning Authorities
with Waste Industry, require clear and consistent guidance from
Scottish Executive. |
| 19 |
Political Agenda |
Changes in political priorities
towards waste management, particularly due to a change of Government/
Local Administration. |
Future government policies
cannot be determined. |
Without full political backing
the AWP will not achieve its objectives. |
Change of Government, change
of Minister, changes in Government Policy, change in Local Administration. |
Keep all political parties
aware of the AWP issues and need for successful implementation,
statutory targets cannot be ignored no matter what administration
is leading. |
| 20 |
Procurement |
Reservations about recycled
product quality, cost and fitness for purpose acting as a barrier
to purchase and application of green procurement policies to close
the resource-use loop. |
Barrier is currently present,
lack of awareness in procurement sector, lack of co-ordinated guidance. |
Continued un-sustainable consumption
of goods, green product prices remain too high, demand for recyclate
remains too low to manage increased material recover. |
Public and private sectors
remain in 'business as usual' scenario. Failure to review contract
arrangements with suppliers or audit % use of recycled materials
in-house, lack of guidance and easy accessible green procurement
information. |
Raise awareness within public
and private sectors on advantages of positive procurement policies
to the environment and sustainable development objectives, need
government/ legislative/ fiscal incentives to ensure manufacturer's
increase recycled content in products/ provide reuse/ refillable
product,s etc. Scottish Executive encourage public sector green
procurement via conditions on public money spending (realising the
significant procurement impact of the public sector and their influence
on suppliers). |
| 21 |
Recyclate Markets |
Recyclate Markets do not
grow to accommodate recovery of additional material. |
Significant extra tonnage
requires to be diverted in next 10 years and beyond into markets
which currently do not exist for some materials and fluctuate for
others. |
The BPEO requires heavy reliance
on markets to accept recovered recyclate. If markets not there,
the BPEO as they currently described will not be delivered. |
Virgin material cheaper;
economy depressed; poor communication and description of market
needs; no priority given to the development of businesses of this
type by government and its agencies, i.e. Scottish Enterprise, lack
of negotiating power to ensure stable supply contracts to reprocessors,
reprocessors setting too high-quality standards on material to be
supplied that cannot be met by BPEO technologies. |
Monitor the development of
recyclate markets, ensure BPEO technologies/ processes encourage
recovery of as high a grade recyclate as possible, consortium joint
working in dealing with reprocessors, support the work of WRAP and
ReMaDe. |
| 22 |
Skills |
Lack of skills - 'Many of
the people working in the waste management industry (public and
private sector) do not have direct experience of advanced waste
management techniques and technologies. |
Such high levels of recycling,
composting and recovery have not been implemented in the UK to date
and practical skills in new technologies are lacking. |
Failure of technologies, facilities
operating at lower capacity/quality of segregation than expected. |
Lack of investment in training.
Not being exposed to new ideas and technologies. |
Technology seminars, visits
to facilities, sharing skills, promotion of WAMITAB - set standards
to operate facilities. |
| 23 |
Unforseen Risks |
e.g. foot and mouth disease/
ABO impact on composting. |
Difficult to plan for probability
of such issues, difficulties arise when other non-waste-related
government departments set down operational requirements that have
major potential knock-on impacts to current BPEO proposals. |
Immediate and large scale
treatment and disposal problems on technologies that are relied
upon to meet legislative requirements. |
Lack of Emergency Planning
measures, Contingency Plans and poor management practices. |
Ability of an integrated
Waste Management system to adapt and be flexible in a crisis. |
