Guidance

SR2022 No 8: waste wood treatment

Published 18 December 2024

Applies to England

© Crown copyright 2024

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The Environmental Permitting (England & Wales) Regulations 2016 

These rules incorporate the following standard rules sets:  

  • SR2011 no 4  

  • SR2015 no 23  

Introductory note 

This introductory note does not form a part of these standard rules. 

When referred to in an environmental permit these rules will allow the operation of a waste facility where non-hazardous waste wood is stored and treated at a specified location, providing that the permitted activities meet the following location criteria: 

  • not within 200 metres of a workplace or dwelling 

  • not within 250 metres of a European site, Ramsar, Site of Special Scientific Interest or Marine Conservation Zone

  • not within 50 metres of a National Nature Reserve, Local Nature Reserve, Local Wildlife Site, Ancient woodland or Scheduled Ancient Monument

  • not within 50 metres of a site that has species or habitats protected under the Biodiversity Action Plan that the Environment Agency considers at risk to this activity

  • not within 10 metres of a watercourse

  • not within a groundwater source protection zone 1

  • an Air Quality Management Area designated for particulate matter PM10 

These rules will permit: 

  • waste types in Table 2.3 to be accepted and processed at the site

  • the total quantity of waste accepted and processed at the site shall be no more than 50,000 tonnes of waste per year

  • sorting, separation, cutting, pulverising, shredding, blending, chipping, pelletising and briquetting

These rules will not permit: 

  • hazardous wastes

  • waste wood to be stored for more than 6 months

  • waste wood of less than 150mm in length to be stored for longer than 3 months 

These rules are linked to the non-hazardous and inert waste: appropriate measures for permitted facilities guidance published on 12 July 2021.  

Words and expressions used in this introductory note and these standard rules shall have the meanings given in section 4.4, as appropriate. 

End of introductory note. 

Rules 

1. Management 

1.1 General management 

1.1.1 The operator shall manage and operate the activities: 

(a) in accordance with a written management system that identifies and minimises risks of pollution, so far as is reasonably practicable, including those risks arising from operations, maintenance, accidents, incidents, non-conformances, closure and those drawn to the attention of the operator as a result of complaints; and 

(b) using sufficient competent persons and resources. 

1.1.2 Records demonstrating compliance with rule 1.1.1 shall be maintained. 

1.1.3 Any person having duties that are or may be affected by the matters set out in these standard rules or the permit shall have convenient access to a copy of the permit and the rules. 

1.1.4 The operator shall comply with the requirements of an approved competence scheme (or other approval issued by the Environment Agency). 

1.2 Avoidance, recovery and disposal of wastes produced by the activities 

1.2.1 The operator shall take appropriate measures to ensure that: 

(a) the waste hierarchy referred to in Article 4 of the Waste Framework Directive is applied to the generation of waste by the activities; and 

(b) any waste generated by the activities is treated in accordance with the waste hierarchy referred to in Article 4 of the Waste Framework Directive; and 

(c) where disposal is necessary, this is undertaken in a manner which minimises its impact on the environment. 

1.2.2 The operator shall review and record at least every four years whether changes to those measures should be made and take any further appropriate measures identified by a review. 

2. Operations 

2.1 Permitted activities 

2.1.1 The operator is only authorised to carry out the activities specified in table 2.1. 

2.1.2 The activities will be undertaken in accordance with appropriate measures specified in the following sections of the non-hazardous and inert waste appropriate measures guidance:  

  • section 2 – General management appropriate measures 

  • section 3 – Waste pre-acceptance, acceptance & tracking 

  • section 4 – Waste storage (sections 4.1 to 4.8) 

  • section 5 – Waste treatment (all except section 5.1 and 5.3) 

  • section 6 – Emissions control (sections 6.3.1 to 6.3.8 and 6.3.16 to 6.3.18. Sections 6.4.3 to 6.4.6 and section 6.5.1 to 6.5.3 and 6.5.5 to 6.5.16) 

  • section 9 – Waste minimisation, recovery and disposal 

2.1.3 All process plant and equipment shall be commissioned, operated, and maintained in accordance with the manufacturer’s recommendations and shall be fully documented and recorded. 

Table 2.1 

Activity reference Description of specified activity Limits of specified activity
AR1- waste wood treatment R3: Recycling/reclamation of organic substances which are not used as solvents (including composting and other biological transformation processes). Treatment is restricted to sorting, separation, cutting, pulverising, shredding, chipping, blending, pelletising and briquetting. 

 No more than 50,000 tonnes of waste wood shall be treated and stored per year.
AR1- storage of waste R13: Storage of waste pending any of the operations numbered R 1 to R 12 (excluding temporary storage, pending collection, on the site where the waste is produced). Waste wood of more than 150mm and above in length shall not be stored for more than 6 months. 

 Waste wood of less than 150mm in length shall not be stored for more than 3 months.

2.2 The site 

2.2.1 The activities shall not extend beyond the site, being the land shown edged in green on the site plan attached to the permit. 

2.2.2 The activities shall not be carried out within: 

(a) 200m of a workplace or residential dwelling; 

(b) 200 metres of a European site, Ramsar, Site of Special Scientific Interest or Marine Conservation Zone; 

(c) 50 metres of a National Nature Reserve, Local Nature Reserve, Local Wildlife Site, Ancient woodland or Scheduled Ancient Monument; 

(d) 50 metres of a site that has species or habitats protected under the Biodiversity Action Plan that the Environment Agency considers at risk to this activity; 

(e) a groundwater source protection zone 1; 

(f) 10 metres of a watercourse; 

(g) an Air Quality Management Area (AQMA) designated for particulate matter PM10.  

2.3 Waste acceptance 

2.3.1 Waste shall only be accepted at the site if all the following apply: 

(a) it is of a type listed in this rule and in Table 2.3; 

(b) it conforms to the description in the documentation supplied by the producer and holder; 

(c) its chemical, physical and biological characteristics make it suitable for the treatment intended for it; and 

(d) in the case of soils other than from domestic premises, road subbase and road planings, you have obtained the following in writing: 

  • information about the pollutants that could be present in the waste; and
  • an assessment to determine if the waste has hazardous properties based on representative sampling and analysis; and
  • confirmation of the appropriate waste code, based on the assessment.

2.3.2 Any waste that does not comply with rule 2.3.1 shall be rejected and: 

  • removed from the site; or
  • moved to a designated quarantine area pending removal.

2.3.3 Records demonstrating compliance with rule 2.3.1 shall be maintained. 

Waste quantities 

2.3.4 The total quantity of waste accepted at the site shall be no more than 50,000 tonnes per year. 

2.4 Operating techniques 

2.4.1 The activities shall be operated using the techniques and, in the manner, described in the following sub-paragraphs. 

Technique 1 

All waste shall be kept secure. 

Technique 2 

All waste shall be kept and treated on an impermeable surface with a sealed drainage system.  

Technique 3 

All sumps, tanks, lagoons, collection points and channels in the drainage system shall be inspected daily and managed to prevent the escape of contaminated water from the site. 

Technique 4 

No more than 750 cubic metres of wood of more than 150mm in length shall be stored in any one stack. 

Technique 5 

No more than 450 cubic metres of wood of between 30 and 150mm in length shall be stored in any one stack. 

Technique 6 

No more than 300 cubic metres of wood of less than 30mm in length shall be stored in any one stack.

Technique 7 

No wood stack shall be higher than 4 metres. 

Technique 8 

Wood stacks shall be located 6 metres or more from each other unless an appropriate fire wall is used with at least 1 metre freeboard. 

Technique 9 

Wood stacks shall be subject to a minimum of weekly monitoring of the surface and internal temperature of the stack, including temperature monitoring when loads are first deposited at the site. 

Technique 10 

Trained staff shall be able to access the site and plant and machinery to move wood as necessary and within 30 minutes of detection of smoke or a fire. 

Technique 11 

Shredding of waste wood to less than 30mm in length shall be carried out within a building. 

Technique 12 

When shredding waste wood: 

  • shredder speed shall be kept as low as practicable to minimise the production of fines and particulates
  • shredders and areas around them shall be inspected daily and managed to prevent the build-up of particulates
  • hoods shall be installed on the shredder outlet points to reduce particulate release
  • drop heights from the shredder outlet points and any conveyors shall be minimised
  • point-source water misting systems or water sprays shall be installed over the shredder hopper and outlet
  • mobile dust suppression units or static misting systems in buildings, shall be used to control point sources of particulates
  • dust suppression systems must be designed, sited, and maintained to minimise generation of particulates across the site

3. Emissions and monitoring 

3.1 Emissions to air 

3.1.1 There shall be no point source emissions to air, water or land except:  

(a) liquids may be discharged into a sewer subject to a consent issued by the local sewerage undertaker;  

(b) liquids may be taken off-site in a tanker for disposal or recovery;  

(c) clean (uncontaminated) surface water from roofs, or from areas of the site that are not being used in connection with storing or handling waste, may be discharged directly to surface waters, or to groundwater by seepage through the soil via a soakaway. 

3.2 Monitoring 

3.2.1 Emissions of substances not controlled by emission limits shall not cause pollution. The operator shall not be taken to have breached this rule if appropriate measures, including, but not limited to, those specified in any approved emissions management plan, have been taken to prevent or where that is not practicable, to minimise, those emissions. 

3.2.2 The operator shall: 

(a) if notified by the Environment Agency that the activities are giving rise to pollution or are likely to do so, submit to the Environment Agency for approval within the period specified, an emissions management plan which identifies, prevents, and minimises the risks of pollution from emissions of substances not controlled by emission limits. 

(b) implement the approved emissions management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.  

3.2.3 All liquids in containers, whose emission to water or land could cause pollution, shall be provided with secondary containment. This must meet CIRIA C736 Containment systems for the prevention of pollution or an equivalent standard. 

3.3 Dust 

3.3.1 Emissions from the activities shall be free from dust at levels likely to cause pollution outside the site, as perceived by an authorised officer of the Environment Agency, unless the operator has used appropriate measures, including, but not limited to, those specified in any approved dust management plan, to prevent or where that is not practicable, to minimise, the dust. 

3.3.2 The operator shall:  

(a) if notified by the Environment Agency that the activities are giving rise to pollution outside the site due to dust, submit to the Environment Agency for approval within the period specified, a dust management plan;  

(b) implement the approved dust management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency. 

3.4 Odour 

3.4.1 Emissions from the activities shall be free from odour at levels likely to cause pollution outside the site, as perceived by an authorised officer of the Environment Agency, unless the operator has used appropriate measures, including, but not limited to, those specified in any approved odour management plan, to prevent or where that is not practicable to minimise the odour. 

3.4.2 The operator shall: 

(a) if notified by the Environment Agency that the activities are giving rise to pollution outside the site due to odour, submit to the Environment Agency for approval within the period specified, a revised odour management plan which identifies and minimises the risks of pollution from odour. 

(b) implement the approved revised odour management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency. 

3.5 Noise and vibration 

3.5.1 Emissions from the activities shall be free from noise and vibration at levels likely to cause pollution outside the site, as perceived by an authorised officer of the Environment Agency, unless the operator has used appropriate measures, including, but not limited to, those specified in any approved noise and vibration management plan to prevent or where that is not practicable to minimise the noise and vibration. 

3.5.2 The operator shall: 

(a) if notified by the Environment Agency that the activities are giving rise to pollution outside the site due to noise and vibration, submit to the Environment Agency for approval within the period specified, a noise and vibration management plan which identifies and minimises the risks of pollution from noise and vibration. 

(b) implement the approved noise and vibration management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency. 

3.6 Fire prevention 

3.6.1 The operator shall take all appropriate measures to prevent fires on site and minimise the risk of pollution from them including, but not limited to, those specified in any approved fire prevention plan. 

3.6.2 The operator shall: 

(a) if notified by the Environment Agency that the activities are giving rise to a risk of fire, submit to the Environment Agency for approval within the period specified, a fire prevention plan which prevents fires and minimises the risk of pollution from fires; 

(b) implement the fire prevention plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency. 

4. Information 

4.1 Records 

4.1.1 All records required to be made by these standard rules shall: 

(a) be legible; 

(b) be made as soon as reasonably practicable; 

(c) if amended, be amended in such a way that the original and any subsequent amendments remain legible, or are capable of retrieval; and 

(d) be retained, unless otherwise agreed in writing by the Environment Agency, for at least 6 years from the date when the records were made, or in the case of the following records until permit surrender: 

  • off-site environmental effects; and  

  • matters which affect the condition of the land and groundwater. 

4.1.2 The operator shall maintain convenient access, in either electronic or hard copy, to the records, plans and management system required to be maintained by this permit. 

4.2 Reporting 

4.2.1 All reports and notifications required by these standard rules shall be made in writing, using the contact details supplied by the Environment Agency. Where reports and notifications must be made immediately they may be provided verbally. 

4.2.2 Within one month of the end of each quarter, the operator shall submit to the Environment Agency using the form made available for the purpose, the information specified on the form relating to the site and the waste accepted and removed from it during the previous quarter. 

4.2.3 The operator shall keep records of the material exported from the site as non-waste including the type of material, the tonnage of material, the batch number and the date of export. This information shall be reported to the Environment Agency within one month of the end of each quarter and the records shall be maintained for at least 2 years. 

4.2.4 In the event: 

(a) that the operation of the activities gives rise to an incident or accident which significantly affects or may significantly affect the environment, the operator must immediately: 

  • inform the Environment Agency; 

  • take the measures necessary to limit the environmental consequences of such an incident or accident; and 

  • take the measures necessary to prevent further possible incidents or accidents. 

(b) of a breach of any rule the operator must immediately: 

  • inform the Environment Agency; and 

  • take the measures necessary to ensure that compliance is restored within the shortest possible time. 

(c) of a breach of any rule which poses an immediate danger to human health or threatens to cause an immediate significant adverse effect on the environment, the operator must immediately suspend the operation of the activities or the relevant part of it until compliance with the permit conditions has been restored.  

4.2.5 Written confirmation of actual or potential pollution incidents and breaches of rules shall be submitted to the Environment Agency within 24 hours. 

4.2.6 Following the detection of an event listed in rule 4.2.4, the operator shall review and where necessary revise the management system and implement any changes as necessary to minimise the risk of reoccurrence of the issue. 

4.3 Notifications 

4.3.1 In the event: 

(a) that the operation of the activities gives rise to an incident or accident which significantly affects or may significantly affect the environment, the operator must immediately: 

  • inform the Environment Agency; 

  • take the measures necessary to limit the environmental consequences of such an incident or accident; and 

  • take the measures necessary to prevent further possible incidents or accidents. 

(b) of a breach of any permit condition the operator must immediately: 

  • inform the Environment Agency; and 

  • take the measures necessary to ensure that compliance is restored within the shortest possible time. 

(c) of a breach of permit condition which poses an immediate danger to human health or threatens to cause an immediate significant adverse effect on the environment, the operator must immediately suspend the operation of the activities or the relevant part of it until compliance with the permit conditions has been restored 

4.3.2 Written confirmation of actual or potential pollution incidents and breaches of emissions shall be submitted within 24 hours. 

4.3.3 Where the Environment Agency has requested in writing that it shall be notified when the operator is to undertake monitoring and, or spot sampling, the operator shall inform the Environment Agency when the relevant monitoring and, or spot sampling is to take place. The operator shall provide this information to the Environment Agency at least 14 days before the date the monitoring is to be undertaken. 

4.3.4 Following the detection of an issue listed in rule 4.2.4 the operator shall review and revise the management system, and implement any changes as necessary to minimise the risk of reoccurrence of the issue. 

4.3.5 The Environment Agency shall be notified within 14 days of the occurrence of the following matters except where such disclosure is prohibited by Stock Exchange rules: 

(a) Where the operator is a registered company: 

  • any change in the operator’s trading name, registered name or registered office address; and 

  • any steps taken with a view to the operator going into administration, entering into a company voluntary arrangement or being wound up. 

(b) Where the operator is a corporate body other than a registered company: 

  • any change in the operator’s name or address; and 

  • any steps taken with a view to the dissolution of the operator. 

(c) In any other case: 

  • the death of any of the named operators (where the operator consists of more than one named individual); 

  • any change in the operator’s name(s) or address(es); and 

  • any steps taken with a view to the operator, or any one of them, going into bankruptcy, entering into a composition or arrangement with creditors, or, in the case of them being in a partnership, dissolving the partnership. 

4.3.6 The operator shall notify the Environment Agency, as soon as is practicable, in writing of any change of new combustion plant or generator at the site. 

4.4 Interpretation 

4.4.1 In these standard rules the expressions listed in 4.4.1 shall have the meanings given. 

‘accident’ means an accident that may result in pollution 

‘Air Quality Management Area’ means an air quality management area within the meaning of the Environment Act 1995 which has been designated due to concerns about particulate matter in the form of PM10. 

‘approved competence scheme’ means a Government approved scheme which demonstrates an appropriate level of technical competence and complies with the conditions of their permit. 

‘authorised officer’ means any person authorised by the Environment Agency under section 108(1) of The Environment Act 1995 to exercise, in accordance with the terms of any such authorisation, any power specified in section 108(4) of that Act. 

‘building’ means a permanent enclosure designed to protect against the weather, minimise noise breakthrough and prevent releases of dust from the building.  

‘CIRIA C736 Containment systems for the prevention of pollution’ means the updated guidance published in 2014.   

‘EP Regulations’ means The Environmental Permitting (England and Wales) Regulations SI 2016 No.1154 and words and expressions used in this rule set which are also used in the Regulations have the same meanings as in those Regulations. 

‘emissions management plan’ (EMP) means a plan which is informed by a risk assessment and which sets out site-specific control measures to prevent and minimise the risk and impact of pollution due to emissions from the site. Different EMPs should be produced for different pollutants, for example, odour, noise and vibration, dust and particulates, mud, litter. These EMPs form part of the site’s management system. 

‘emissions of substances not controlled by emission limits’ means emissions of substances to air, water or land from the activities, either from the emission points specified in these standard rules or from other localised or diffuse sources, which are not controlled by an emission or background concentration limit. 

‘European site’ means a European site within the meaning of Regulation 8 of the Conservation of Habitats and Species Regulations 2017, and refers to a candidate or Special Area of Conservation and proposed or Special Protection Area in England and Wales.  

‘freeboard’ means the measurement between the top of the stack or pile and the top of the firewall, and from the leading edge of the stack or pile and the front of the firewall. 

‘groundwater’ means all water, which is below the surface of the ground in the saturation zone and in direct contact with the ground or subsoil. 

‘groundwater source protection zone 1’ means a zone within 50m of a point at which water is abstracted for domestic or food production purposes from any underground strata, or defined by a 50-day travel time for groundwater to reach a groundwater abstraction point that is used to supply water for domestic or food production purposes, whichever is larger. 

‘handling’ includes all activities relating to waste except for its storage and included treatment as well as transfer activities like loading, unloading and movement of waste within the site. 

‘impermeable surface’ means a surface or pavement constructed and maintained to a standard sufficient to prevent the transmission of liquids through and beyond the pavement surface, and should be read in conjunction with the term ‘sealed drainage system’. 

‘List of wastes’ means the list of wastes established by Commission Decision 2000/532/EC replacing Decision 94/3/EC establishing a list of wastes pursuant to Article 1(a) of Council Directive 75/442/EEC on waste and Council Decision 94/904/EC establishing a list of hazardous waste pursuant to Article 1(4) of Council Directive 91/689/EEC on hazardous waste, as amended from time to time (including by decision 2014/955/EU). 

‘Marine Conservation Zone’, designated under the Marine and Coastal Access Act 2009. 

‘Non-hazardous and inert waste: appropriate measures guidance’ means the Non-hazardous and inert waste: appropriate measures for permitted facilities guidance first published 12 July 2021 and updated on 1 August 2023. 

‘pollution’ means emissions as a result of human activity which may:  

  • be harmful to human health or the quality of the environment
  • cause offence to a human sense
  • result in damage to material property, or
  • impair or interfere with amenities and other legitimate uses of the environment.

‘quarter’ means a calendar year quarter commencing on 1 January, 1 April, 1 July or 1 October. 

‘R’ means a recovery operation provided for in Annex II to Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on Waste. 

‘recovery’ means any of the operations provided for in Annex IIB to Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on Waste. 

‘sealed drainage system’ in relation to an impermeable surface means a drainage system with impermeable components which does not leak and which will ensure that: 

  • no liquid will run off the surface otherwise than via the system; 

  • except where they may lawfully be discharged to foul sewer, all liquids entering the system are collected in a sealed sump. 

‘secure’ means that all reasonable precautions are taken to ensure that the waste cannot escape and that members of the public are unable to gain access to the waste. 

‘SSSI’ means Site of Special Scientific Interest within the meaning of the Wildlife and Countryside Act 1981 (as amended by the Countryside and Rights of Way Act 2000). 

‘stack’ – dimensions of the wood stack (or the wood pile) and the length of wood items in that stack.  This should be taken as approximate measurements.  Whilst the stack will contain a range of individual wood items of different lengths down to fines, the amount of wood in that stack should, on balance, be of the length or the longest axis, specified.  

‘waste code’ means the six digit code referable to a type of waste in accordance with the List of Wastes.  

‘workplace or residential dwelling’ means a place where people are likely to be present for more than 6 hours at any one time. This does not apply to the operators of the permitted facility, their staff when they are at work or to visitors to the facility, as their health is covered by Health and Safety at Work legislation. 

‘year’ means calendar year ending 31 December. 

Waste types

Table 2.3 Waste codes and descriptions  

02 Wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing, food preparation and processing

Waste code Description
02 01 wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing.
02 01 03 wood and bark
02 01 07 wood and bark

03 Wastes from wood processing and the production of panels and furniture, pulp, paper and production

Waste code Description
03 01 wastes from wood processing and the production of panels and furniture
03 01 01 bark and cork
03 01 05 sawdust, shavings, cuttings, wood, particle board and veneer other than those mentioned in 03 01 04
03 03 wastes from pulp, paper and cardboard production and processing
03 03 01 bark and wood

15 Waste packaging, absorbents, wiping cloths, filter materials and protective clothing not otherwise specified

Waste code Description
15 01 packaging (including separately collected municipal packaging waste)
15 01 03 wooden packaging

17 Construction and demolition wastes (including excavated soil from contaminated sites)

Waste code Description
17 02 wood, glass and plastic
17 02 01 wood

19 12 Wastes from the mechanical treatment of waste (for example sorting, crushing, compacting, pelletising) not otherwise specified

Waste code Description
19 12 07 wood other than that mentioned in 19 12 06

20 Municipal wastes (household waste and similar commercial, industrial and institutional wastes) including separately collected fractions

Waste code Description
20 01 separately collected fractions (except 15 01)
20 01 38 wood other than that mentioned in 20 01 37
20 02 garden and park wastes (including cemetery waste)
20 02 01 wood and bark

End of standard rules.

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