Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence

Memorandum submitted by the Chartered Institution of Wastes Management


  1.1  The Chartered Institution of Wastes Management (CIWM) is pleased to provide the following comments to the Select Committee in their enquiry into the future of waste management

  1.2  CIWM is the pre-eminent body for waste managers in the UK, with a membership base of over 5,000 individuals from all areas of the waste industry including organisations that produce or manage waste, educational and research establishments, environmental consultancies, Local Authorities, waste equipment manufacturers/suppliers, waste collection or disposal companies, and waste regulators. CIWM sets professional standards for individuals working in the waste management industry and its objectives are to: Advance the scientific, technical and practical aspects of wastes management for the safeguarding of the environment; Promote education, training, research and the dissemination of knowledge in all matters of wastes management; Strive to achieve and maintain the highest standards of practice, competence and conduct by all its members. CIWM provides professional impartial representation on all waste matters.

  1.3  CIWM has a unique position in the industry having an extensive membership and representation across all sectors, which enables CIWM to draw on that expertise. In our response to this consultation exercise, as a result of time and word constraints, we have chosen to focus on a number of more pertinent issues. We would however be happy to provide further information on request and would be prepared to provide verbal evidence.


  2.1  CIWM believes that waste minimisation is ultimately concerned with resource availability and consumption. However achieving this in practice poses a challenge to all stakeholders. Commercial and industrial waste minimisation generally occurs as a result of good in-house practices and is driven by market forces (the bigger the company the greater the economies of scale and the easier it is to undertake these practices). Many good examples exist of specific industry sectors and organisations implementing waste minimisation procedures, which have provided an economic and environmental gain. However, there is still considerable scope for improvement. More effective and wider dissemination of examples of good practice and guidelines for achieving practical waste minimisation should be a priority, and the work of Envirowise or similar organisations should be supported further.

  2.2  The use of benchmarking for waste minimisation in the commercial and industrial waste sector should be promoted. This could be through the further development of self-regulatory tools such as Environmental Reporting. It has been found in a review of priorities for companies publishing environmental reports and setting policy that waste management scored the highest in terms of topics covered in future plans and targets. Environmental reporting makes organisations more aware of the waste they produce and also provides the opportunity to benchmark their waste management practices each year. Environmental reporting is considered as a useful tool in changing practices and increasing reuse and recycling, so much so that a number of countries have now implemented mandatory environmental reporting, either targeted at specific sectors or sizes of organisations. The government has challenged industry to provide more comprehensive environmental reporting, but it remains a voluntary activity to date, generally taken up by specific sectors keen to prove their environmental credentials. We therefore support the recommendation to consider the value of mandatory environmental reporting. In addition, a higher profile of environmental management systems, through ISO/EMAS certification is supported.

  2.3  A major issue is that the vast majority of businesses are SME's, who do not have the same knowledge of their waste generation and management and have little or no incentive to change behaviour. As individual organisations they will be producing relatively small quantities of waste, but collectively they will be contributing a significant quantity to landfill disposal. We therefore support the Strategy Unit recommendation to increase the role of waste minimisation clubs, as they have an essential role to play in changing behaviour particularly within this sector. In addition it is paramount that training and education for waste producers is paramount if change is to be achieved in the medium term. Nowhere is this need for training and education more obvious than the hazardous waste sector. Recent and forthcoming changes in legislation have imposed restrictions on the options available for hazardous waste producers and therefore clearer guidance is essential. We look forward to contributing to the DEFRA Hazardous Waste Forum, and receiving clarification on the Environment Agency's position on a potential Hazardous Waste Strategy.

  2.4  Little or no incentives currently exist at the household level for waste minimisation. "Shop smart" is one of only a few opportunities for consumers to minimise their waste. There have been a number of local level initiatives but their success has been limited to date. It is therefore imperative that measures are taken to increase responsibility at the household level. Rather than consumers refusing to purchase certain goods with excess packaging we should be looking to encourage lifestyle changes, which minimise the potential and actual generation of waste. CIWM supports the need for a nationally coordinated campaign and it is imperative that organisations such as the National Waste Awareness Initiative are resourced sufficiently to meet their aims and objectives. Whilst the Government has ruled out the introduction of a national tax on household waste CIWM supports Local Government having the power to develop innovative waste minimisation solutions, thereby removing restrictions on local authorities to directly charge for municipal waste collected. Variable and direct charging at the household level are widely used across Europe and are accepted as one of the best tools to induce positive behaviour amongst householders and increase recycling rates. CIWM advocates the implementation of direct charging, specifically identifying a charge for the collection and disposal of MSW to each household, as opposed to its inclusion within the Council Tax. Once this approach is in place this can be followed by the introduction of variable charging, whereby the household pays a fee related to the quantity of waste generated. CIWM is fully supportive of the use of this type of instrument as long as the necessary support structures are in place, specifically appropriate information provision in addition to a well-developed recycling infrastructure.

  2.5  Despite the implementation of the EC Packaging Waste Directive, producer responsibility has achieved limited success in the UK; this is set to increase in the near future with the implementation of a number of policy initiatives and Directives. The deliverability, for example, of the End of Life Vehicles Directive, and the Waste from Electrical and Electronic Equipment Directive, may well hinge on effective producer responsibility regulations at national level. In addition, in an effort to attain higher levels of waste recycling, there may be a move towards implementing producer responsibility at the household level, through variable charging.


  3.1  Many factors contribute to the disappointing level of recycling currently being achieved in the UK. We supported the move from voluntary to statutory recycling targets and think they should be challenging but achievable. We have some concerns that the high achieving local authorities will face difficulties in further increasing their recycling rates. It is considered easier in both practical and economic terms to put a new scheme in place and improve upon a low baseline recycling rate, compared to improving systems already in place. It is essential that support is offered to the high achievers and that they do not face the same type of penalties as the low achievers in terms of satisfying interim targets.

  3.2  Whilst we support the higher recycling and composting targets proposed in the SU report, which are not unrealistic given the intended changes to the regulatory and economic framework, however they are only achievable if the necessary infrastructure is in place in a timely fashion.

  3.3  As the pressure is increasing on Local Authorities to boost their recycling performance, meet best value targets, and divert material away from landfill, kerbside collection schemes have been seen to be a more efficient way of capturing recyclables from the household waste stream, rather than relying on bring or drop off systems. Cost and local circumstances are usually limiting factors in terms of the type of kerbside scheme adopted, however there is a plethora of material available on best practice throughout the UK and overseas and it is now possible to develop a kerbside collection scheme to suit a range of different local conditions. Experience has shown that prior to and following implementation of a kerbside scheme, regular information and education provision is paramount to its success. However the convenience of well operated kerbside schemes does ensure that it is an effective approach to maximising collection of recyclables and boosting local recycling rates. We therefore fully support the recommendation in the SU report for a roll out of kerbside recycling schemes.

  3.4  Adequate funding to local authorities for infrastructure development is essential—the gap between the funding available to Local Authorities and the need for expenditure to meet sustainable waste objectives, is widening. The £140 million Challenge Fund was a start, however the value of the fund was insufficient to meet the needs of all local authorities. There is concern that the current funding mechanisms, through the EPCS block, may not be the most appropriate and whether ring fenced funds would be more suitable to ensure that waste management receives the resources needed.

  3.5  As an Institution we have long advocated greater producer responsibility and we therefore support the increase of incentives for reuse and the promotion of the use of secondary resources and environmentally friendly products, in addition to the development of green procurement initiatives

  3.6  Waste exchanges are an option for diverting hazardous, industrial, or commercial waste from final disposal and promoting reuse or recycling. Exchanges have achieved varying degrees of success in Europe and beyond but in the UK they are currently underused and can essentially be described as a waste "dating service". Waste exchanges generally operate on a low key basis in the UK and deal in very small quantities of waste and as such awareness of their operations is limited. The Environment Agency has set itself a policy to encourage waste exchanges and facilitate networks however there has been no real evidence of this to date. There are a number of waste exchanges currently operational in the UK and we support the recommendation to explore the potential for supporting the wider development of waste exchanges.


  4.1  Whilst CIWM supports the ethos of the waste hierarchy in terms of moving towards more sustainable management of waste, this should not been seen as a prescriptive process. Selecting the best environmental option, taking into account life cycle assessment, should always be the preferred approach.

  4.2  National strategies should be cognisant of the potential role of all elements of the hierarchy. There are numerous examples of good practice from overseas where high levels recycling have been accompanied by high levels of energy recovery from waste. However, options needed to deal with residual waste have tended to have been perceived rather negatively, making planning and investment more difficult. Clear government support needs to be given for all options on the waste hierarchy, promoting those at the top, but with acceptance for an integrated approach to allow residual waste to be managed in an environmental manner.

  4.3  CIWM is fully supportive of utilising energy from waste as a viable waste management option and has an active Thermal Treatment Special Interest Group, and Energy from Waste Technical Working Group focusing on these issues.

  4.4  Health studies to date have shown that incineration does not pose a significant risk and that causal links cannot be identified for landfill sites and health incidents. It is essential that further health studies continue to be undertaken to address perceived fears and enable scientific judgements to be made. However, when data and information is presented it is paramount that it is done so in a contextual manner, and that all options for managing waste are investigated, not just traditional disposal routes.


  5.1  Funding as ever remains a priority for waste management and is fundamental to the delivery of more sustainable waste management. It is generally accepted that householders have little understanding of the costs associated with MSW management and charges are currently insufficient to meet the needs for infrastructure development. The SU report has identified costs associated with the implementation of priority areas, however, aside from the existing routes of funding currently available and the changes to landfill tax and the landfill tax credit scheme, no additional funds have so far been agreed. All stakeholders in waste management are united on the issue that funding is a priority if we are to move towards a more sustainable way of managing waste. CIWM recommends a need for ring fencing and implementation of direct charging as a first step towards variable charging at the household level in order to meet the funding requirements for waste management.


  6.1  The Pre-budget report raised the landfill tax by just £3.00 per tonne, per year from 2005-06. Prior to the Pre Budget Report expectation amongst the industry was high as it was anticipated that there would be a significant increase in the level of tax to bring the UK more in line with its European neighbours. CIWM has been key amongst a wide range of stakeholders, who, whilst supporting the landfill tax in principle, have called for much higher levels if its aim of diverting material away from landfill is to be realised. Currently set at £13.00 per tonne, on an escalator over the next two years to £15.00 per tonne, it was anticipated that a doubling of the level of tax would be needed to put the cost of landfill disposal on par with, or higher than, alterative waste management options, thereby presenting a more level playing field. More importantly, a higher tax would present more opportunities for hypothecation of the taxes into sustainable waste management initiatives. The Chancellor announced that a taxation level of £35.00 per tonne would be a long-term aim. However, the problem with long-term fiscal instruments is that they are not in tune with short-term targets in the landfill directive and statutory recycling targets. Whilst any increase in the landfill tax could be viewed as demonstrating positive support from the government, the reality is that a £3.00 per tonne escalator will do little to promote further diversion from landfill or provide sufficient funds for infrastructure development through the landfill tax credit scheme. We are disappointed and will proactively urge Government on behalf of our members to review the level of escalator set, and promote the figure of £35.00 per tonne to be a short-medium rather than long term target.

  6.2  The pre-budget report also confirmed reform of the Landfill Tax Credit Scheme with a third of the funding continuing to be available for spending on community environment projects and two thirds to be allocated to public spending to encourage sustainable waste management. Whilst the advantages of allocating a proportion of the funds to the public sector can be appreciated, there are concerns relating to the uncertain future for other areas currently funded by the credit scheme, such as research, and information and dissemination, which have been hugely beneficial to waste management. There are also concerns relating to the knock-on effect a lack of funding for specific projects will have on employment and accessing external funds (refer to the discussion held at the December meeting of the Associate Parliamentary Sustainable Waste Group).

7.  DATA

  7.1  The need for accurate and reliable data has long been identified by the industry as a major barrier to progress and is an issue highlighted at various times throughout the SU report. All the stakeholders will therefore be supportive of the recommendation for the Environment Agency and DEFRA to draw up a data and research strategy for the next three years. This needs to take into account existing projects, for example, Dataflow which demonstrates both a good use of landfill tax credits and is also an example of industry, and government departments, working together and actively redressing the deficiency in MSW data.


  8.1  With regard to the role of Local Government, whilst there are a number of good examples of joint municipal waste strategies, this is by no means universal. Therefore CIWM support the continual incentivising of local authorities to work together. The possible medium term option of developing unitary resource management authorities, combining the role of waste collection and disposal authorities, as proposed by the SU report, builds on the previous implementation of unitary authorities. CIWM will continue to debate this issue both internally with members from all sectors and externally with key stakeholders, including the Local Government Association.


  9.1  The level of training in the waste management industry has been criticised in previous reports. CIWM now provides 118 days of training per year, covering all practical and legislative aspects of waste management. However, in terms of moving up the hierarchy and developing more sustainable waste management practices, there is an urgent requirement for training at all levels. Whilst a number of strategies are already in place for training those in the waste industry itself (NVQ's at all levels etc.), there is also a need to extend the focus to waste producers.


  10.1  CIWM supports the need for an overhaul of the planning system and related policies. Currently the planning process poses a significant barrier to the development of essential facilities to treat waste and therefore this has significant implications on movement up the hierarchy. This is particularly the case for re-use/recycling facilities. There is an urgent need for the development of generic responses identifying the government position, and including objective data and information.


  11.1  There is a need for a strengthened role, and higher profile, of waste in government. In addition there needs to be full utilisation of existing policy and legislation, and improved enforcement by the Environment Agency.

  11.2  CIWM welcomed the first step towards recognising the very real barriers to meeting statutory requirements when the Secretary of State held the Waste Summit last year. As the second step, the Strategy Unit Report takes the debate further and identifies solutions to overcome the barriers. The Institution now looks forward to the implementation of the recommendations as the third step in the process and remains committed to playing our role in their delivery and maintaining the momentum of interest amongst the decision makers and key stakeholders.

Chartered Institution of Wastes Management

6 January 2003

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