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Guidance on the appropriate measures for the biological treatment of waste in England

Paul Wright Technical Director
Paul Wright

Paul’s previous experience as NRW Industry Regulation Team Leader for North and Mid Wales gives him unrivalled insight into the requirements of environmental permitting and compliance, and in particular, knowledge of how the approach to engagement and improvement can influence the natured timing of Regulator actions. This is complemented by a detailed understanding of industrial business operations gained through over 20 years’ experience of operational and technical management of various sites across a range of industrial sectors.

The Environment Agency (EA) recently held a consultation on draft guidance for ‘Appropriate measures for the biological treatment of waste’ in England. This draft guidance is designed to help operators understand which standards (appropriate measures) are relevant to regulated facilities with environmental permits to treat organic waste. The draft guidance applies to aerobic and anaerobic processes and includes:

  • composting in open-air and closed processes;
  • aerobic processing of organic fractions in mechanical and biological treatment (MBT) and mechanical heat treatment (MHT);
  • thermophilic aerobic digestion (TAD);
  • Anaerobic digestion (AD) including the combustion or upgrading of the resulting biogas and treating the digestate, (anaerobic treatment can include wet, dry and dry-batch digestion);
  • storing recovered materials (compost and digestate);
  • aerated lagoons and activated sludge (as a wastewater treatment); and
  • treating sewage sludge using any of the above biological processes.

The draft guidance, if adopted, will replace the following existing guidance notes:

  • How to comply with your environmental permit: Additional guidance for anaerobic digestion. Reference LIT 8737, version 1, November 2013
  • How to comply with your environmental permit: Additional guidance for composting and aerobic treatment sector. Reference LIT 8705, version 1, November 2013
  • How to comply with your environmental permit: Additional technical guidance for mechanical biological treatment (MBT). Reference LIT 8707, version 1, August 2013
  • Framework for assessing suitability of wastes going to anaerobic digestion, composting and biological treatment. Framework guidance note dated July 2013

How does this affect your site?

If your site treats biological waste by one of the techniques listed above, then you will have until August 2022 to comply with the relevant guidance. New sites must comply with the guidance from commencement of their operations.

Below we highlight some of the potential new measures required by this draft guidance:

  • Requirement for an up-to-date Environmental Management System
  • Biogas Flares to be rated at 1000oC
  • All new containment to be CIRIA C736 compliant
  • A chartered civil or structural engineer must provide construction quality assurance (CQA) and validate the construction of all facilities
  • A chartered geotechnical engineer can be used for lagoon design and construction
  • All existing containment to be risk assessed
  • All lagoons and digestate stores to be covered
  • Pressure relief valves/vents to be checked periodically for leakage to atmosphere
  • Backup generators to be fitted or provision made for swift connection
  • New facilities must consider at the design stage, the opportunity to cover storage areas and where possible contain and abate air using appropriately engineered plant
  • Existing facilities must review their activities to identify opportunities to cover equipment and processes and contain and abate emissions
  • Mandatory DSEAR (Dangerous Substances and Explosive Atmosphere Regulations) assessments for all installations

SLR have the broad range of skills and expertise to be able to assist you in assessing how the draft Appropriate measures for the biological treatment of waste guidance may affect you and assisting you with complying.

For more information please contact Paul Wright (Technical Director - Environment Management, Permitting & Compliance) at: or Tony Yates (Technical Director – Process Engineering) at