Memorandum submitted by Cleanaway Limited
INTRODUCTION
1. Cleanaway is a global waste management
and recycling organisation employing 15,500 people, with operations
spanning 14 countries on three continents. It is a wholly owned
subsidiary of Brambles, a global industrial services company listed
on the London and Sydney stock exchanges.
2. In the UK the company operates one if
the largest collection services for commercial, industrial and
hazardous wastes through a specialist fleet of over 1,700 vehicles.
The wide range of services offered to local authorities and industrial
and commercial clients cover a broad spectrum including waste
recovery, recycling, collection, disposal, high temperature incineration
and advice on Best Practice.
SUMMARY OF
CLEANAWAY RECOMMENDATIONS
— We believe that the hierarchy is
a useful guide but it should not be seen as a goal in itself.
— We would strongly recommend that
any measures for promoting the waste hierarchy should deal with
hazardous and non-hazardous wastes separately.
— Manufacturers should be compelled
to use the most appropriate packaging materials to aid recovery.
— In order to send out a clearer message
to the public, the term "waste avoidance" is recommended
in preference to "waste minimisation".
— Each household should be provided
with the facilities for separate collection of recyclables, putrescibles
and residuals.
— The principle of BPEO should be applied
to individual hazardous waste categories.
— The principle of BAT should be applied
to all waste management processes.
— The Environment Agency should apply
strict waste acceptance criteria to landfills to prevent cheap,
low-tech disposal options being allowed to continue.
— Government action to stimulate and
drive a predictable reuse and recycle market is essential.
THE WASTE
HIERARCHY—FUNDAMENTAL
ISSUES
3. The Waste Framework Directive (the Directive)
sets out a number of fundamental principles that affect the management
of wastes and no one Article of that Directive should be taken
in isolation. If the Directive is read as a whole, the waste hierarchy
becomes one piece of a bigger picture and not a "holy grail"
to be pursued at any cost.
4. Article 4 of the Directive reflects the
sentiment of Paragraph three of the preamble to that Directive
and states; Member States shall take the necessary measures to
ensure that waste is recovered or disposed of without endangering
human health and without using processes or methods which could
harm the environment. The over-riding requirement for all waste
management operations to safeguard human health and protect the
environment needs to be regarded as seriously as the Article 3
exhortation for movement of wastes up the hierarchy.
5. The concept of the waste hierarchy has
been developed since the publication of the Directive. Indeed,
three versions of the hierarchy are published in the Strategy
Unit's Report. It suggests that the hierarchy is a useful framework
that has become a cornerstone of sustainable waste management.
However, there has been an increasing tendency for this simple
version of the hierarchy to be used rigidly, for example, in taking
decisions on planning applications such that perfectly sensible
proposals have been refused. This has been on the basis that all
aspects of a proposal must be higher up the hierarchy to the extent
that simple disposal would not be allowed. It is almost inevitable
that the disposal of some residues will always be required.
6. It is also unfortunate that the simple
triangular diagrammatic representation of the hierarchy has led
to an over simplification of the approach promulgated in the Directive.
The impression frequently given by government, especially in Waste
Strategy 2000, is that if waste is recycled or composted or if
value is recovered from it, then this is acceptable. There has
been very little emphasis on the prevention of waste or consideration
of environmental benefit.
7. The word "minimisation" is
commonly used and is frequently used in the Strategy Unit Report.
This seems to be an unfortunate choice as it is never used in
its true sense, ie to reduce to the least possible amount. It
actually gives the impression, and seems to be used in the sense,
that the production of waste is acceptable provided some measure
is taken subsequently to recover value from it and in which case,
it is the disposal of waste that is minimised, rather than its
generation in the first place. This seems to be a "mind set"
that perpetuates the growth in waste production because waste
is seen to be acceptable provided measures are taken to recover
it.
8. In the Directive, the emphasis is placed
on prevention. The recovery of waste is the second stage, when
preventative measures cannot be instigated. The preventative measures
require the development of cleaner technologies, more sparing
in their use of natural resources. Following that, the development
and marketing of products should make the smallest possible contribution
to increasing the amount or harmfulness of waste and pollution
hazards. This approach points to a much more careful consideration
of the use of materials in production than is hinted at in the
Strategy Unit Report.
9. The issues surrounding moving hazardous
wastes up the hierarchy are quite different, and in some ways
more complex than those surrounding non-hazardous wastes. There
is a European Directive relating specifically to the management
of hazardous wastes, and hazardous wastes are more diverse in
their physical and chemical properties than non-hazardous wastes.
Because hazardous wastes have been recognised as having the greatest
potential to cause serious harm and pollution they need special
consideration.
10. We would strongly recommend that any
measures for promoting the waste hierarchy should deal with non-hazardous
wastes and hazardous separately.
NON-HAZARDOUS
WASTE
11. At page 14 of the Strategy Unit Report,
it is suggested that producers and retailers need to reduce the
amount of waste they produce and pass on less waste through the
supply chain to customers and use recycled materials where possible.
A much stronger emphasis must be placed on establishing the most
appropriate materials to be used in terms of energy consumption
and resources needed to produce them, to reduce the volume and
mass once produced and to produce materials that can be easily
recycled. Life cycle assessments need to be carried out on a whole
range of products and packaging, this would then lead to the initial
concept of waste "avoidance" followed by the use of
materials that can most easily be recycled.
12. A large proportion of the household
waste stream is packaging. "Bring" and "kerbside
collection" systems are increasingly allowing the recycling
of some of the packaging materials. However, there should not
be such a proliferation of different materials used in containers
for packaging. There should be much more careful consideration
of the optimum materials to be used for each packaging requirement.
For example, soft drinks can be supplied in glass bottles, plastics
bottles, cartons or cans and within each of those container types,
there will be significant variations in materials. There must
be an optimum material taking into account the initial use of
resources, the ease of use and the ease of recycling. If the correct
material were properly assessed, legal measures could be taken
to compel manufacturers to use only the most appropriate materials.
If this necessitated charging deposits on the containers, then
this should also be enforced.
13. It might be argued that this would be
an infringement of civil liberties but this would be no different
to the imposition of environmental taxes or, for example, the
application of lower speed limits to reduce polluting vehicle
emissions.
14. In order to educate the public and send
out a clearer message, the term "waste avoidance" is
recommended in preference to waste minimisation or waste reduction
since this implies stopping the creating of waste rather than
accepting its production and possibly recycling it.
15. The first part of the waste hierarchy
in the Waste Framework Directive concerns waste avoidance. The
second part concerns recycling, reuse or reclamation and the use
of waste as a source of energy. Once containers have been optimised
in terms of reducing use of resources and of facilitating recycling,
then the logistics of recycling have to be solved. Again, there
must be an optimum method to organise the collection and processing
of materials for recycling and composting. The way the Government
has approached recovery is to leave it to individual collection
authorities with vague targets to be achieved. If a national system
were decided upon and implemented, then the costs would be reduced
by the economies of scale and consistency. Each household should
be provided with a three-compartment bin or three separate, different
coloured bins for the separate collection of:
16. This could be supported by legal obligations
requiring the use of the systems by the public and offences for
misusing the system. Again, arguments about civil liberties do
not carry great weight since similar legislation has been in place
for many decades restricting what can be discharged into public
sewers. Collection authorities could convert to vehicles to receive
the wastes from three compartment bins or collect each type of
material separately. Such an approach would have to be supported
by national campaigns of education and information distribution
leading to a change in cultural attitudes towards waste and litter
so as to discourage fly tipping. This could be amplified by more
serious attempts at prosecution and imposition of well-publicised
draconian punishments. It should be made clear that environmental
crimes such as fly tipping are completely inexcusable and will
attract maximum levels of punishment. For example, if a person
uses a car for fly tipping, then their car could be impounded
until the appropriate fine is paid.
17. In order for the materials to be processed
and recycled, large numbers of processing facilities will be required
in every town. Compliance with the Waste Strategy targets will
not be achieved unless changes are made to the planning system
that will allow these facilities to be provided. Most industries
can move into premises that have permission for general industrial
use. Light industrial use would cover a wide variety of food processing
industries, yet waste management and composting are regarded as
"sui generis", so requiring specific planning permission
for the distinct use. If this restriction were removed, not only
would the provision of the facilities be accelerated, the costs
involved would be reduced by avoiding the expense of specific
planning applications and inquiries and the construction of specific
buildings. Existing warehouses designated for light industrial
use would be ideal for MRFs and for in-vessel composting plants.
Maturation of compost could also be carried out in such a building.
Currently, only storage of matured compost can be carried out
in such buildings (since matured compost would be equivalent to
goods and that would be covered by light industrial usage).
18. The limitation of the use of premises
for waste management generates some absurd situations, stifling
development and recovery. For example, premises that have permission
for the production and distribution of electronic equipment could
not be used to receive and reprocess the very same equipment because
it would be regarded as waste.
19. Even if recyclable materials and putrescible
materials are separately collected and reprocessed, it is still
necessary to find a method of disposal of the residuals. The materials
remaining are comprised essentially of card, paper and plastics
contaminated by foodstuffs. These carry inherent public health
risks and would be very difficult, if not impossible, to reprocess.
The environmental benefit of reprocessing would be questionable
because of the significant additional use of resources to produce
a low-grade material with little scope for reuse.
20. Cleanaway has useful experience in considering
environmental benefits of reprocessing waste materials. We operate
two plants taking waste PET drinks bottles and reprocessing them
into food grade PET chips. This process is only viable because
the reprocessing returns the materials to the original high value
use. Capturing these materials for low-grade use would not justify
the further consumption of energy, water and chemicals in the
regeneration process (or the cost). However, this is using large
quantities (for economies of scale) of source-segregated materials
that are not heavily contaminated. The reprocessing of mixed contaminated
materials would be much more difficult and would be an inefficient
use of resources.
21. If landfill is not to be used for such
residuals, the only realistic disposal option is incineration
with the recovery of energy. Incineration of petroleum based substances
such as plastics would at least give rise to energy generation
as a second use. The combustion of fibre-based materials is almost
neutral in terms of CO2 emissions so can be considered environmentally
sustainable, displacing the consumption of fossil fuels. With
the latest European Waste Incineration Directive, there can be
no argument against incineration on the basis of emissions.
HAZARDOUS WASTE
22. Due to the very fact that these wastes
are hazardous and have the potential to cause harm, the over-riding
requirement for all waste management operations to safeguard human
health and protect the environment (Article 4) needs to be regarded
even more seriously in comparison with the Article 3 exhortation
for movement of wastes up the hierarchy.
23. This is not currently the case, as exemplified
by the enormous growth of calorific hazardous wastes being burned
in old, dirty industrial processes like cement kilns—an
activity which carries the "recovery" tag and is thus
preferred by hazardous waste producers over modern, clean high
temperature incinerators which also require fuels but are currently
tagged as "disposal" processes.
24. The way forward to avoid inadvertently
polluting the environment by blinkered support for any process
which purports to be higher up the waste management hierarchy,
is to apply the principle of BPEO (Best Practicable Environmental
Option) to the hazardous waste categories in the EU Waste Catalogue
and be prescriptive about the preferred management route for each
type of waste. Similarly, the principle of BAT (Beat Available
Technology) should be applied to all waste management processes—including
those which claim to operate higher up the hierarchy—to
avoid bringing recovery and recycling processes into disrepute
by allowing dangerous or polluting processes to masquerade as
sustainable waste management options.
25. For the traditional high volume waste
streams emanating mainly from process industries, the high costs
of hazardous waste management have traditionally driven waste
minimisation programmes in this sector, and high costs of waste
management will continue to be the major driver for reduced-waste
process technologies in the future. It is important for the UK
to maintain a strong indigenous chemical industry (£4 billion
a year balance of payments benefit to the UK), care is therefore
needed to avoid driving multi-national companies' production abroad
by imposing too high a cost burden in the UK, however more needs
be done to close off cheap waste management options.
26. The Landfill Directive has already had
a noticeable effect on the way hazardous waste producers are planning
their future operations—they are reducing waste production,
building on-site waste treatment plants, and planning cleaner
technologies for the future. It is important that the Environment
Agency applies strict waste acceptance criteria to hazardous waste
landfills in England and Wales (within the site-specific "risk
analyses" allowed by the European Commission's criteria for
acceptance of waste allowed at hazardous landfill sites) to avoid
existing cheap disposal options for hazardous waste continuing
into the future.
27. The other remaining "cheap"
disposal option for process industry hazardous wastes is the blending
of liquid wastes into cement kiln fuels, an activity which in
itself purports to be a "recovery" route for wastes.
Genuine solvent recycling in the UK has suffered from having to
compete with this waste management route since 1993, and hazardous
solvent wastes have moved down the hierarchy from recycling to
"recovery" as a result. The way to ensure that only
those wastes for which blending is the BPEO follow this route
is to apply the BPEO test to all hazardous wastes in the European
catalogue, and regulate the producers to ensure that the BPEO
is used in every case. This will minimise the use of this remaining
"cheap", sometimes free of charge, option in an environmentally
sound way and promote minimisation of waste in the long term.
28. As regards re-use, recycling and recovery
of hazardous wastes emanating from the process industry, there
are currently few opportunities for this activity to be commercially
viable. Significant volumes (particularly of low value materials)
of long-life waste streams are required to justify these niche
process developments. Only waste solvents, waste oils, valuable
metal-containing wastes and some inorganic acid waste streams
have met these criteria in the past.
29. In order to increase the types, and
therefore the quantities, of organic hazardous wastes being re-used
or re-cycled, it is most likely that biological processes will
be the most productive (c.f. ICI's commercial process for producing
single cell protein (SCP) as a constituent for pig food by feeding
Methanobacter on waste methanol in the 1980s—Shell also
developed a similar biological process with an oil based feed).
This area is one where government pump-priming for the viable
waste stream identification and subsequent process development
would be useful.
30. Inorganic wastes are much more stream
specific, in that they tend to have lower potential value (except
precious and semi-precious metal wastes) and in most cases are
more difficult to purify and separate. Some of the inorganic hazardous
wastes, including waste gypsum emanating from high volume flue
gas cleaning processes (eg coal fired power station de-sulphurisation
plants), have potential for sustainable recycling—Government
could help encourage this.
31. Turning to the hierarchy for manufactured
hazardous wastes (eg brake and clutch linings, fluorescent light
tubes, batteries etc), the key for minimising these wastes is
in their manufacturing, and in the manufacturing of the larger
items of which they become a component. Manufacturing less battery
operated devices (eg clockwork radios, mains-only electric shavers
etc) would help, although it is appreciated that this would be
a difficult culture change to achieve in a consumer society, increasingly
dependent on electronic goods. Changing designs to do away with
parts that produce a "hazardous" waste at end-of-life
is another way forward (eg non-hazardous brake shoes).
32. Manufacture for longer life of all of
the items which become hazardous waste at end-of-life should also
be encouraged to minimise waste volumes: producer responsibility
for the cost of waste management for these items will encourage
this. As for re-use, recycling and recovery of these hazardous
wastes, producer responsibility should also drive manufacturers
to agree standardised material usage and production techniques
which facilitate the separation for re-use, recycling or recovery
of the various components of these hazardous wastes. For instance,
non-rechargeable batteries that are both fit for purpose and easier
to recycle could be developed, and it is possible governments
could help this process by judicious funding of targeted research
and/or development grants. In most cases, there already exists
the technology and expertise to dismantle and/or separate re-usable
materials from these goods; the problem is making these sometimes
difficult reverse engineering processes economically viable.
33. Government action to stimulate a predictable
re-use market for the products of these dismantling and separation
processes is one way of making these activities attractive to
industry and thus increase the amount of hazardous waste which
is re-used, recycled or recovered.
Cleanaway
6 January 2003
| 
