Managing unused waste COVID-19 PPE: RPS C30
Updated 1 July 2023
Applies to England
This regulatory position statement (RPS) does not change your legal requirement to comply with an environmental permit or waste exemption when you store, de-package, dismantle, treat and use unused waste COVID-19 personal protective equipment (PPE).
However, the Environment Agency will not normally take enforcement action against you if you do not comply with these legal requirements provided that:
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your activity meets the description set out in this RPS
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you comply with the conditions set out in this RPS
In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
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cause a risk to water, air, soil, plants or animals
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cause a nuisance through noise or odours
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adversely affect the countryside or places of special interest
Activity this RPS applies to
This RPS applies:
- to storing, de-packaging, dismantling, treating and using unused waste PPE at a facility designated by the Department of Health and Social Care (DHSC)
- where waste codes 15 02 03 ‘personal protective equipment’ and 16 03 06 ‘off specification batches and unused products’ are not in your environmental permit or you operate under a T4 waste exemption: preparatory treatments, such as, baling, sorting, shredding or a U9 waste exemption: using waste to manufacture finished goods
Conditions you must comply with
You must either:
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hold an environmental permit that authorises the treatment or use of waste plastics
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have a registered T4 or U9 waste exemption
You must:
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be a facility designated and approved by the DHSC
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store, treat or use waste made up of unused waste PPE classified as 15 02 03 or 16 03 06 in line with technical guidance WM3
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operate in line with your environmental permit, or the limits and conditions specified in the T4 or U9 waste exemption you have registered
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store and treat the unused waste PPE indoors
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only store unused waste PPE where it will be treated or used on site
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submit a written monthly update to wastetreatment@environment-agency.gov.uk for each agreed site to include the quantity (in tonnes) of:
- PPE accepted at each site
- waste removed from site broken down by European waste catalogue (EWC) and disposal or recovery code
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keep records for 2 years to show that you have complied with this RPS and make these records available to the Environment Agency on request
You must not:
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operate under this RPS until you have received written agreement from the Environment Agency
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store 15 02 03 and 16 03 06 wastes for longer than 3 months
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exceed the tonnage limit for plastic in your environmental permit, or your T4 or U9 waste exemption
Things to note
You must not claim packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) for waste PPE or non-waste PPE.
When you must check back
This RPS will expire on 31 December 2024.
The Environment Agency can withdraw or amend this regulatory position before the expiry date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.
You will need to check back from time to time, including at and before the expiry date, to see if this RPS still applies.
This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.
If you cannot comply with this RPS
If you operate under this RPS but can no longer comply with it, you must stop the activity to which this RPS relates and must tell the Environment Agency immediately by emailing wastetreatment@environment-agency.gov.uk.
Contact the Environment Agency
If you have any questions about this RPS email wastetreatment@environment-agency.gov.uk.