Consultation response: Merseyside Recycling and Waste Authority Proposed Changes

Merseyside Recycling and Waste Authority (MRWA) is consulting on four proposed changes to how residents access and use “rubbish tips” across Merseyside. Part of this includes asbestos. Rather obviously, this has to be easy to do; otherwise, people may simply break up their Asbestos-Containing Material (ACM), put it into numerous black bin bags and dump it. The current Asbestos Disposal Service seems to be suitable and sufficient, so we would not like this to be adversely affected by any forthcoming changes to waste services following the consultation.

Whilst asbestos was banned in 1999, its widespread historic use means that we are concerned that the amount of asbestos in domestic settings is greatly underestimated. Many householders are unaware of their legal obligations, though of greater concern are the dangers they may be presenting to younger members of their families through exposure to asbestos fibres, which can have a devastating, life-changing, or even life-taking effect in the future.

The old, corrugated ACM garage or shed roof that has been there for years may be assumed by many householders to be the end of their potential contact with asbestos. Some may think that, now asbestos-containing brakes, gaskets or clutch fittings are no longer used, they have no further contact with asbestos at home. They may not realise that asbestos was also used in wood burners, slow cookers, hair dryers, portable heaters, textured paint and wall coverings, around boilers, roofing felt or in vermiculite insulation, etc.

Those who work within the waste industry or with the consequences of asbestos-related illnesses such as mesothelioma are clearly aware that such waste is hazardous and cannot be disposed of with standard construction waste. All asbestos-containing materials must be securely packaged, clearly labelled and taken to a licensed disposal facility.

The disposal of asbestos waste has to remain as easy as reasonably practicable for householders, as we do not want to encourage illegal dumping. Illegal disposal poses serious health risks and carries significant penalties.

Illegal dumping remains a serious asbestos waste disposal issue. Asbestos can be fly-tipped in a range of locations, creating potential risks to human health and the environment. More broadly, the Environment Agency has identified financial incentives within waste crime, including illegal operators undercutting legitimate businesses, and the involvement of organised criminal groups in illegal waste operations. Criminal operators may present themselves as legitimate waste operators while disposing of waste unlawfully for profit.

We would like to see a system where ACM waste is suitably and safely prepared, bagged and labelled by the householder, in accordance with the latest HSE guidelines, but then collected by the MRWA’s chosen licensed waste receiver. The consignment note system would create an auditable trail, although the householder may need advice on completing the consignment notes from the receiver.

Suitable, up-to-date HSE-supported advice and equipment could enable householders to develop a greater understanding of fibre-control measures. Bite-sized online training, perhaps even with a small completion certificate to accompany the consignment notes, could be considered. AI may also make asbestos awareness information easier to access than ever before. Such a system could assist with the enforcement of asbestos waste regulations, lessen the opportunity for operators who cut corners to offer lower prices, discourage illegal fly-tipping and help eliminate unqualified operators.

Merseyside Asbestos Victims Support Group (MAVSG), Registered Charity No. 1178373, would welcome the opportunity to be involved in any future campaigns to improve domestic asbestos awareness across Merseyside and can be contacted on 0151 236 1895 or at info@mavsg.org.

Derek Maylor Hon FIIAI FSRPH MIIRSM MRi

Trustee – Merseyside Asbestos Victims Support Group
derek.maylor@btinternet.com
07761 098 993

15 August 2026

Consultation response:

· Merseyside Recycling and Waste Authority. (2026). Help Shape the Future of Household Waste Recycling Centres in Merseyside. [Online]. Available at: www.merseysidewda.gov.uk/hwrc-consultation/. [Accessed 15 August 2026].

Sources:

· Health and Safety Executive (HSE). Asbestos – FAQs. [Online]. Available at: www.hse.gov.uk/asbestos/faq.htm. [Accessed 15 August 2026].

· GOV.UK. Asbestos in your home. [Online]. Available at: www.gov.uk/asbestos-in-home. [Accessed 15 August 2026].

· Health and Safety Executive (HSE). A38 – How to deal with fly-tipped asbestos waste. Asbestos Essentials. [Online]. Available at: www.hse.gov.uk/pubns/guidance/a38.pdf. [Accessed 18 August 2026].

· Environment Agency. (2026). How the Joint Unit for Waste Crime is dismantling organised crime in the UK waste industry. [Online]. Available at: environmentagency.blog.gov.uk/2026/07/29/how-the-joint-unit-for-waste-crime-is-dismantling-organised-crime-in-the-uk-waste-industry/. [Accessed 18 August 2026].

· Environment Agency. (2026). Response document: Charge proposals for reducing waste crime and updating time and materials charges. GOV.UK. [Online]. Available at: www.gov.uk/government/consultations/environment-agency-charge-proposals-for-waste-crime-and-hourly-rates. [Accessed 18 August 2026].

· HSE – HSG247 covers the safe removal of asbestos-containing materials in construction.

· HSE – HSG264 provides guidance on survey requirements and asbestos management.