When appropriate measures apply

Assessing appropriate measures for your site, the measures that apply to different types of facilities and implementing measures at new and existing facilities.

There is a lot of overlap between best available techniques (BAT) for waste installation facilities and necessary measures for waste operation facilities. The Environment Agency uses the term ‘appropriate measures’ to cover both sets of requirements.

Appropriate measures are the standards that operators should meet to comply with their environmental permit requirements. This guidance sets out what you must consider when you assess the appropriate measures for your site. It is not definitive and it does not replace your obligation to assess appropriate measures fully.

Some measures may not be suitable or relevant for your operation. Appropriate measures will depend on the:

  • activities being carried out
  • size and nature of the activities
  • location of the site

For installations there are additional requirements for using energy and raw materials (including water) efficiently. These are called process efficiency measures.

Where a measure is not suitable, an operator can propose alternative measures that achieve the same level of environmental protection. Or they can provide an explanation of why the specific measure is not relevant.

In certain situations, you may need to provide a higher standard of environmental protection, for example:

  • where there are local sensitive receptors
  • if there is a risk that an operator may exceed an Environmental Quality Standard

Measures that apply to different types of facilities

This is how the standards in this guidance apply to different types of facilities that treat or transfer healthcare waste.

The following sections apply to transfer stations:

The following sections apply to alternative treatment activities (treating healthcare wastes by a method other than incineration):

For healthcare waste incineration activities, the following sections apply in addition to the Incineration sector guidance:

Other generic technical guidance also applies to healthcare waste facilities, including guidance on emissions, odour and noise.

Specific technical guidance may also be appropriate. For example, additional technical guidance is available for operators of sites that incinerate waste and operators who store or treat other chemical hazardous wastes.

We consider the accident and fire prevention measures specified in this guidance are appropriate measures for managing the fire risks of healthcare waste. If you have a permit to carry out an activity involving the storage of other non-hazardous combustible wastes, you may need an approved fire prevention plan that meets the requirements of our guidance.

Combustion plant with a rated thermal input less than 50 megawatts must comply with the relevant requirements of the Medium Combustion Plant Directive and specified generator regulations. See guidance on the requirements.

If you operate an exempt site that transfers or treats healthcare waste you should also follow this guidance.

Implementing appropriate measures at new and existing facilities

The appropriate measures in this guidance apply to both new and existing facilities that treat or transfer healthcare waste.

For new facilities the appropriate measures must be in place before operations start.

For existing facilities, if the cost of complying with the appropriate measures is disproportionate to the environmental benefit, immediate compliance may not be reasonable. Through permit reviews, the Environment Agency will assess the current operating techniques of existing facilities against the relevant appropriate measures.

Where an operator is not using appropriate measures, we will expect them to provide improvement plans and timetables for implementing the relevant appropriate measures. We will review these proposals and set formal timescales for making the improvements needed. We will do this by varying the environmental permit to include improvement conditions.

Improvements at existing facilities are likely to fall into one of the following 2 categories.

Standard good practice requirements

For example, these could be:

  • updated management systems
  • waste, water and energy efficiency measures
  • measures to prevent fugitive or accidental emissions
  • waste handling techniques
  • appropriate monitoring equipment

Where these improvements are relatively low cost, operators should implement them as soon as possible and within 12 months.

Larger, more capital intensive improvements

For example, these could be:

  • installing significant abatement equipment
  • the significant redesign of facility layout, including the design and installation of new buildings or treatment plant

Operators should complete these improvements as soon as practicable and within 3 years.

Local environmental impacts (for example, having sensitive receptors or an air quality management area close by) may mean an operator has to take action more quickly than the timescales provided here.

By August 2022, unless we approve a derogation, existing installations must comply with relevant BAT Associated Emission Levels (AELs). These are set out in the published Waste treatment BAT conclusions document.

New installations (including new or replacement plant at existing facilities) must comply with any relevant BAT AELs from when operations begin, unless a derogation is approved.