Reopening Household Waste Recycling Centres (HWRCs)
As part of our work to transition towards a ’new normal’, it is necessary to consider how HWRCs can be re-opened safely. This will require consideration of a range of factors to ensure that physical distancing is maintained, the public continue to be encouraged to make only essential journeys, and other key waste services are not negatively impacted.
It is important to recognise that reopening HWRCs may increase pressure on other waste services which are already stretched at this time and that further reprioritisation of services may be necessary.
Local Authorities have statutory obligations to provide waste collection and disposal services, including an obligation under section 1 of the Refuse Disposal (Amenity) Act 1978 to provide a site where household waste can be deposited. Recent announcements from the Scottish Government and COSLA acknowledge the work underway by Local Authorities to reopen HWRC sites from 1 June. This position may need to be re-visited should this be necessary in order to protect public health. The Coronavirus (COVID-19): framework for decision making outlines how we make decisions on reopening businesses and services.
This is provided as guidance only and does not amount to legal advice. Local Authorities and commercial operators may wish to seek their own advice to ensure compliance with all legal requirements.
Restrictions on movement
We are grateful to residents who have done all they can to reduce demand on waste services throughout this crisis by taking steps to minimise waste or by storing waste at home. These actions and decisions by Local Authorities to close HWRCs have undoubtedly reduced non-essential journeys and helped stop the spread of the virus.
There is, however, a limit to how much waste can be stored at home and households may be producing more waste than usual at this time. Additionally, some residents may not currently have access to some collection services.
COSLA has confirmed that all local councils are working towards the re-starting of some HWRC services on 1 June 2020 in line with the phasing outlined through “Coronavirus (COVID-19): framework for decision making - Scotland's route map through and out of the crisis”. This is of course subject to change if the COVID-19 infection rate does not continue to improve. While Scottish Government advice will change so that there is no longer a restriction on the public travelling outside the home for the purpose of using a HWRC, this does not mean that all HWRCs will or should necessarily reopen. There are wider considerations, such as the ability to operate a site safely under the current circumstances, which may prevent some specific sites from reopening. Work is now underway in Local Authorities across the country to prepare for the re-opening of sites where appropriate.
Health and safety requirements
HWRCs must be operated in a way that protects the health and safety of the public and staff. The measures required will vary depending on site-specific factors such as layout, location and the facilities available on-site. Detailed guidance on COVID-19 and waste management activities has been produced by the Waste Industry Safety and Health (WISH) Forum, providing advice on key issues including risk assessment, cleaning and hygiene, Personal Protective Equipment (PPE) and workforce management. The Health and Safety Executive has also issued guidance on working safely (links to which can be found at further information - annex B) and Health Protection Scotland has published COVID-19 guidance for non-healthcare settings
Local Authorities are updating their risk assessment for each site which includes consideration of:
- their duty to ensure physical distancing can be maintained in line with Health Protection Scotland and Scottish Government guidance on physical distancing (further information - annex B). The feasibility of maintaining physical distancing will depend to some extent on site-specific factors regarding layout and facilities.
- procedures for using facilities, ensuring such procedures are understood by staff and communicated to the public. This may include, for example, the introduction of new arrangements for limiting the number of vehicles allowed on-site.
- changes to the site plan in order to improve throughput.
- additional staffing requirements, including training needs, to manage both the site and queueing traffic.
- changes to the cleaning regime in line with relevant guidance including that issued by the WISH Forum (further information - annex B), particularly for surfaces that the public and staff are likely to come into contact with.
- PPE requirements in line with relevant guidance including that issued by the WISH Forum (further information - annex B).
- the availability of hygiene facilities, such as hand-washing facilities or hand-sanitisation stations, for staff in line with relevant guidance including that issued by the WISH Forum (further information - annex B).
- procedures for dealing with conflict and where individuals fail to adhere to physical distancing requirements.
Operational considerations for reopening HWRCs
While decisions regarding the opening and operation of HWRCs are a matter for individual Local Authorities, it is recognised that a coordinated approach to reinstating services is important to manage public demand and avoid unintended consequences. Collaboration between Local Authorities is therefore encouraged, and a checklist of suggested actions is available in annex C.
When preparing plans for the re-introduction of HWRCs, Local Authorities should also seek input and agreement on the plan from:
- site contractors/operators
- Police Scotland
- relevant roads authorities
- trades unions
- reprocessing and disposal facilities and
- other council services such as roads, street sweeping and enforcement officers.
Key considerations agreed by Local Authorities and Scottish Government include:
Which sites can be opened
This will depend on several factors including the availability of resources, site location, the potential issues caused by queuing traffic, and the ability to operate the site safely for the public and staff. Sharing this information with neighbouring authorities will allow for better prediction of demand issues at sites close to authority boundaries.
Sites should be operated in line with Scottish Government guidance for business and the principles outlined in the Fair Work Statement issued by Scottish Government and the Scottish Trades Union Congress. Police Scotland are also encouraging Local Authorities to contact their respective Local Policing Divisions to ensure that the local arrangements put in place are suitable. There is a range of guidance which may be useful to Local Authorities in considering this issue (further information - annex B) and collaboration across Local Authorities is encouraged to support the development of effective practice.
In addition to physical distancing measures and operational procedures to ensure staff safety (for example, steps to ensure good hygiene), measures may be necessary to ensure that staff wellbeing and mental health are protected and that staff are safeguarded from abuse. Additional procedures are also likely to be necessary to maintain staff safety where members of the public require assistance.
State of readiness of site and staff
Local Authorities have established an achievable timeline of 1 June 2020 to resume operations at some sites, in line with the phasing outlined through “Coronavirus (COVID-19): framework for decision making - Scotland's route map through and out of the crisis”. The intention is, so far as possible, to ensure a coordinated recovery across Scotland and a level of geographical coverage. This timeline has been established through consideration of factors such as site preparation, the need to reengage contractors, and additional training required to support safe operation of facilities.
The waste streams that will be accepted once the site reopens
This could include identifying the types and likely quantities of materials that can be collected at each site given available resources and physical distancing guidelines. It may also be worth considering how and when this may develop over the medium to long term.
State of readiness of the supply chain
Liaising with reprocessors/disposers will help to ensure that there is capacity and availability to collect and process the waste collected at HWRCs, particularly given the likelihood that sites will need to be cleared more regularly if there is an initial increase in demand.
Feasibility of actions to manage demand for services before HWRCs reopen
This could include, for example, reinstating or increasing the frequency of bulky and green waste uplifts following appropriate risk assessment.
Actions to reduce demand for services after reopening
This may include a communications plan, in line with key messaging detailed below and options to reduce journeys from outside of the Local Authority area to ensure the demand does not exceed the capacity of the site.
The increased demand and reduced throughput capacity of HWRCs at this time could lead to traffic issues. To mitigate these issues Local Authorities may wish to liaise with Police Scotland to consider relevant and proportionate traffic management plans and any other mitigating actions.
Regular review of processes
Embedding a commitment to review processes regularly within site plans is recommended. This could include a review of the restrictions in place on site and the material streams accepted.