Industry Insight: Environmental Crime and Enforcements Policy


Here at ACM, we try our hardest to offset any waste increases. We do this by being prepared for waste management industry developments or innovations. Russ Sampson, our Principal Environmental Consultant in the North West promotes that he is aware of the developments and changes which are made year on year. Russ continually monitors his clients’ accounts, in order to help them prepare for waste management industry developments that may impact the regions in which we operate.

We asked Russ Sampson CMIWM to shares his industry insights

Environmental Crime and Enforcement Policy

With waste costs at an all-time high, large amounts of money are being made by unscrupulous operators and criminal gangs who typically avoid waste disposal costs by ‘storing’ baled waste in large warehouses, fields and open spaces. They will disguise this waste as Refuse Derived Fuel (RDF).  Unsurprisingly the gangs vanish without trace and without paying for the disposal or management of the waste, and then place the business into liquidation or set fire to the material.  This major scourge has been widely reported in the press and ultimately costs land owners and the taxpayer many hundreds of thousands to manage and clean up.  The Environment Agency has indicated that as well as pursuing criminal gangs, it will also pursue the initial waste producer along with the carriers of the materials that end up in these illegal tips.  The original waste producer may be left in a situation where he has paid a contractor for the initial disposal of the waste, and must then pay again to have it removed from the unauthorised site, and to dispose of it properly (whether this be through recycling or landfill).  It is now more important than ever for a waste producer to demonstrate exactly where their waste has been taken to by the contractor, due to new developments it is no longer good enough to say that they just gave it to a registered contractor.

Recent changes to sentencing guidelines have seen a step change in the enforcement landscape for environmental offences as fines are now levied on an ‘affordability’ basis.  Earlier this year Thames Water was hit with a record breaking fine of £20m for polluting the River Thames, and in August last year Starbucks received a £160k fine for leaving rubbish bags out on the busy streets of Westminster.  Comprehensive tracking portals such as ACM’s ESP and Waste Track® systems enable our clients to demonstrate a fully compliant cradle to grave audit trail, although these should not be confused with inferior ‘depot’ based packages, which are used by some waste contractors. Here at ACM, we will soon be announcing ACM’s new Assure™ package, for those clients who are looking to further protect their organisation and board of Directors against the risks of litigation in higher profile businesses.

Client information is monitored against KPI’s to ensure that we continue to deliver best value for the client for example, by remaining within contracted allowances, introducing innovations and ensuring recycling and wastes continue to be collected by the most effective waste collection contractors in terms of cost, service and environmental performance.


If you would like further advice regarding any aspect of strategic waste management, please do not hesitate to contact Russ directly - or 07903 805180.


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