Guidance

Storing and physically treating hazardous metal shredder residues: RPS 274

Updated 14 March 2025

Applies to England

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This publication is available at https://www.gov.uk/government/publications/storing-and-physically-treating-hazardous-metal-shredder-residues-rps-274/storing-and-physically-treating-hazardous-metal-shredder-residues-rps-274

This regulatory position statement (RPS) does not change your legal requirement to have an environmental permit with the correct waste codes when you store or physically treat hazardous metal shredder residues.

However, the Environment Agency will not normally take enforcement action against you if you do not comply with these legal requirements 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 storing and physically treating hazardous metal shredder residues coded and described as:

  • 19 10 03* fluff-light fraction and dust containing hazardous substances
  • 19 10 05* other fractions containing hazardous substances

(An asterisk at the end of a code means the waste is hazardous.)

Conditions you must comply with

You must:

  • operate your site under a permit which authorises you to accept and physically treat metal shredder residues, coded as 19 10 04 or 19 10 06 (or both)
  • have applied to change (vary) your permit to include 19 10 03* or 19 10 05* (or both) by 1 April 2024
  • have the correct level of technical competence to cover accepting and physically treating hazardous shredder residues within 12 months of the issue of the permit variation to include 19 10 03* or 19 10 05* (or both)
  • make sure that metal shredder residues are coded and consigned as 19 10 03* or 19 10 05* (or both), unless you can prove that the metal shredder residue is non-hazardous waste through sampling and characterisation in accordance with technical guidance WM3
  • make sure that metal shredder residues are coded and consigned as 19 10 03* or 19 10 05* (or both), unless you can prove that the metal shredder residue is non-hazardous waste through sampling and characterisation in accordance with technical guidance WM3
  • make sure that metal shredder residues coded as 19 10 03* or 19 10 05* are handled and stored in accordance with the current permit requirements for 19 10 04 or 19 10 06 (or both)
  • keep records for 3 years to show that you have complied with this RPS and make these records available to the Environment Agency on request

You must not accept any metal shredder residues coded as 19 10 04 or 19 10 06 (or both) unless you can prove that it is non-hazardous waste through sampling and characterisation in accordance with technical guidance WM3.

You must not use this RPS if your application to vary your permit to include 19 10 03* or 19 10 05* (or both) it was:

  • refused
  • returned to you as incomplete (not ‘duly made’)
  • submitted after the 1 April 2024

Things to note

Varying your permit to add hazardous waste codes may change the technical competence requirements for your permit. For example, the operator of a permitted site currently treating non-hazardous metal wastes, may currently hold a CIWM Level 4 Medium Risk Operator Competence for Non-Hazardous Waste Treatment and Transfer (MROC1) qualification. By varying your permit to add hazardous waste codes, the correct qualification would be CIWM Level 4 Medium Risk Operator Competence for Physical Treatment (MROC2).

Under this RPS, you will have 12 months from permit variation issue to gain the right qualification. More information can be found on the CIWM qualifications website. You can continue to handle metal shredder residues, coded as 19 10 04 or 19 10 06 (or both) until your permit variation has been issued. 

If your permit variation is not duly made or your application is rejected, you must stop taking 19 10 03* or 19 10 05* (or both) within one month of your rejection notification.

When you must check back

The Environment Agency will review this RPS by 31 March 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. 

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has 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 wastetreatment@environment-agency.gov.uk and put ‘RPS 274 shredder residues’ in the subject.

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