RPS 212 – Clarity for volunteer groups, or just a way to regulate those who step in when the authorities can’t ?
Regulatory Position Statements (RPS) are issued by the Environment Agency to cover aspects of waste and environmental management not explicitly covered by existing legislation. RPS’ allow individuals or companies to carry out waste management activities without the requirement of an environmental permit, whilst adhering to specific, pre-determined conditions. They are often temporary and are introduced to provide a level of compliance whilst long term solutions are investigated.
What is RPS 212?
RPS 212 applies to volunteers who collect, bulk up, transport and store litter produced during litter collection events. It allows volunteers to:
- transport the litter collected from voluntary litter picking events to a collection point, or to a permitted site that stores similar waste types, such as a household waste recycling centre (HWRC) without registering as a waste carrier or completing a waste transfer note
- temporarily store the collected litter in a secure place
- take the collected litter to a permitted site that stores similar waste types, such as a HWRC where waste code 20 03 03 – litter is not listed on the permit
It also allows the collected litter to be accepted by a permitted site that stores similar waste types, such as a HWRC.
Volunteer litter picking is becoming commonplace in communities all across the UK, as consciousness around environmental issues increases. Waste collected in this way would correctly be classified as litter (EWC Code 20 03 03), a code not widely accepted by HWRC permits.
Why is it needed?
As mentioned previously, litter is classified as 20 03 03, but this EWC code is not widely accepted at HWRCs. Additionally, collected volumes can be such that the volunteer groups have the inability to actually remove the waste to a HWRC, instead leaving it for the Local Authority to collect (tantamount to fly tipping).
Conditions
As with all RPS’ certain conditions have to be met in order to remain compliant. Users of RPS 212 must:
- store the collected litter securely so that it cannot escape, and members of the public cannot gain access to it
- keep records for 2 years to show that you have complied with this RPS and make these records available to the Environment Agency on request
They must not:
- store the collected litter at any temporary site for more than 5 days before removal to a suitable permitted waste site
- collect or at any temporary site store litter containing hazardous waste
- collect or at any temporary site store more than 10 tonnes of litter at any one time.
RPS 212 provides much needed clarity for the growing number of volunteer litter pickers in England’s communities. More focus needs to be directed at behaviours and why people discard litter, and the actions and resources required to prevent littering. We should not be reliant on volunteers to address the symptoms of these problems but need to do more in society to make it socially unacceptable.
RPS 212 will be in place until 30 April 2025 at which point it will be reviewed. Note this RPS only applies to England.
Further information can be found at the Environment Agency website.
