The latest published data on the amount of clinical waste incinerated has revealed a number of inconsistencies which could lead to potential ramifications for the measurement of this material for UK ETS, if it is to be included as proposed in the recent consultation

Two data sets are made available by the Environment Agency for England that are relevant to the incineration of Clinical Waste: Waste Data Interrogator (WDI) and Annual Performance Reports (APR) - both of which are based on data provided by the permit holder/operator of the site. The graph below shows the inconsistencies between both of the data sets with Clinical Waste Incinerators under-reporting in WDI data compared to APR data and MSW (Municipal Solid Waste) incinerators under-reporting in APR data compared to WDI data.

The primary reason for under reporting by Clinical Waste Incinerators is that at least five sites submitted an APR but did not submit any WDI data to the regulator. The impact may be slightly less than shown given that at least three operators appear to only report net combusted tonnage in their WDI data.

The under reporting in MSW incinerators appears to be linked to facilities reporting clinical waste as part of their Household/Local Authority Waste and Commercial & Industrial Waste categories in their APR. By not separating out the clinical waste, it appears that tonnage is under-reported by c.44,750 tonnes, with five sites accounting for c.44,200 tonnes of this figure (i.e. 99%) in APR data when compared to their WDI data.

WDI data is not available for 2023 as yet but, comparing the APR data for 2022 to 2023, it appears that clinical waste incineration has increased, per the graph below, by up to 25% on a like for like basis.

Due to the lag in data published by the Environment Agency, it is unreasonable to assume what the WDI will say for 2023, but, for 2022, it can be seen that the total clinical waste tonnage incinerated is not c.127k tonnes per WDI, but is likely to be closer to c.165k tonnes - equivalent to c.30% more than reported in the WDI data, and with MSW incineration accounting for 49% of clinical waste incinerated.

With the UK ETS consultation minded to included hazardous and clinical waste incineration, there are some concerns that arise:

• The proposed sampling approach for clinical waste incinerators are more 'relaxed' (being based on emission factors alone) than that proposed for the larger MSW incinerators and larger hazardous waste incinerators - creating a potential imbalance in the market

• Whilst the overall proportion of clinical waste in MSW incineration in relatively small, it is nearly half of all incineration of this material, and so the potential to create an imbalance is significant

• The current proposed sampling approach for the five MSW incinerators (incinerating the 'lions share' of clinical waste tonnage) would potentially include compositional analysis assessments as part of their sampling requirements (either as part of their emissions measurement and/or as part of the pass-back to customers)

• It seems that for this particular waste stream, default emission factors should be used in all incineration solutions, bearing in mind the health issues associated with sampling and the need to have consistency in approach to limit any market imbalances

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