Guidance

Shredding waste upholstered domestic seating containing POPs: RPS 264

Updated 6 February 2025

Applies to England

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This publication is available at https://www.gov.uk/government/publications/shredding-waste-upholstered-domestic-seating-containing-pops-rps-264/shredding-waste-upholstered-domestic-seating-containing-pops-rps-264

This regulatory position statement (RPS) does not change your legal requirement to take all reasonable steps to avoid contaminating other waste with persistent organic pollutants (POPs) when you shred waste upholstered domestic seating at a waste treatment site.

However, the Environment Agency will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • your activity meets the description set out in this RPS

  • 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:

  • cause a risk to water, air, soil, plants or animals

  • cause a nuisance through noise or odours

  • adversely affect the countryside or places of special interest

Activity this RPS applies to

This RPS applies to waste treatment sites that have a permit to store and shred waste upholstered domestic seating (WUDS) waste code 20 03 07.

Conditions you must comply with

You must:

  • have already notified the Environment Agency of your intention to use both RPS 264 and RPS 297 before 1 December 2024

  • agree a fugitive monitoring plan for your shredding process with the Environment Agency

  • monitor the fugitive emissions from shredding waste upholstered domestic seating in line with the agreed fugitive monitoring plan

  • email the results of the fugitive emissions monitoring to the Environment Agency at popsinsofas@environment-agency.gov.uk 

  • store and shred WUDS on an impermeable surface and prevent water contaminated with particulates from shredding WUDS entering drainage systems

  • shred WUDS inside a building or within a temporary waste storage shelter which is enclosed on 3 sides with a roof

  • store the shredded WUDS inside a building, in a sealed container, or bale and securely wrap it

  • send the shredded WUDS and fractions from the shredding process for destruction at an appropriately authorised Industrial Emissions Directive Chapter 4 compliant permitted incinerator

  • commission and install equipment to capture and abate fugitive emissions by 1 December 2026 if your monitoring results indicate fugitive emissions need abatement

  • keep records for 2 years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the Environment Agency on request

You must minimise fugitive dust emissions from shredding waste upholstered domestic seating. Examples of methods you can use include:

  • installing mist and spray over the shredder hopper, conveyor system and within buildings
  • installing hoods on shredder outlets
  • reducing how far the shredded material drops from conveyor systems into the storage areas
  • using dust suppression canons or sprays to control point source emissions of particulates
  • adding binders to stockpiles of shredded material and to floors, for example calcium magnesium acetate
  • cleaning the shredder and areas around it regularly to prevent build-up of particulates
  • using wind reduction netting or lamella curtains in wide doorways

Things to note

If you accept WUDS, unless you have written evidence based on x-ray fluorescence (XRF) scanning that it does not contain POPs, you must manage it as if it contains POPs. Further guidance is available about managing WUDS containing POPS.

This RPS has been updated to include the requirements of RPS 297 monitoring fugitive emissions from shredding waste upholstered domestic seating.  

When you must check back

The Environment Agency will review this RPS by 1 December 2026.

The Environment Agency can withdraw or amend this regulatory position before the review 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 review date, to see if this RPS still applies.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn.

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:

Contact the Environment Agency

If you have any questions about this RPS email popsinsofas@environment-agency.gov.uk and put RPS 264 in the subject.

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