Memorandum submitted by BAN Waste (Waste
29)
We are grateful for the opportunity to comment
on this issue.
We consider that there are a number of overarching
principles upon which the Government should be basing its waste
minimisation policy:
— The prevention of hazardous chemicals
from entering the material supply chain
— Waste reduction measures including
producer responsibility measures and eco-design
— The development of infrastructure
and markets for services and products which promote waste minimisation
— The promotion of waste reduction,
product repair, re-use, recycling and composting services
We are concerned that prevention of hazardous
chemicals from being produced does not appear to be a high priority
for the Government as this would seem to us to be a fundamental
element of a resource based waste management policy.
WS2007 makes considerable reference to waste
prevention however we are concerned that current Government proposals
may simply result in a switch from landfill to energy recovery
at the expense of higher options. This would make a move to the
next step up much harder. If waste minimisation is to be achieved
and landfill and incineration prevented, then a great deal of
new policy, legislation and incentives now need to be introduced.
In our view, the Government needs to harness
a range of policies in order to create the circumstances for a
resource management and sustainable consumption strategy to flourish.
There are a number of approaches which we believe could be considered
by the Government to strengthen uptake of waste prevention and
minimisation measures. In particular we would highlight the role
played by:
— Fiscal incentives, disincentives
and support
— Behaviour change systems (eg incentive
schemes)
— Sustainable procurement policies
— Statutory waste minimisation targets,
re-use/repair/return targets and source separation targets for
local authorities, commercial and industrial organisations.
— Infrastructure and market development
— General public information and awareness
raising campaigns (targeting both children and adults)
— The development of information, education,
training and advice services to support commercial and industrial
sectors, local authorities, government and enforcement agencies.
— Assessment, inspection and enforcement
practices
Policies to reduce and prevent waste need to
be strengthened and targeted at:
— Householders and school children
— The extraction, commercial, manufacturing,
industrial and trading sectors
— Government bodies and Local authorities
and
— Enforcement agencies (Health and
Safety, Environment Agency, Customs and Excise and Trading Standards)
The chosen mix of regulatory budgetary, fiscal
instruments, procurement and enforcement measures will need to
trigger change without threats of short term inflationary shocks
(as prices are raised to offset environmental costs and taxes)
or unemployment (as UK businesses move overseas or cease production
rather than compliance with tougher environmental standards).
We urge the Government to seriously explore
the important role to be played by regulatory and fiscal measures.
The Government does appear to recognise the
importance of education and training and we welcome the wide range
of initiatives that the Government has introduced over the last
five years.
We are concerned about the bias of funding support
in favour of large, capital-intensive waste, re-use and recycling
initiatives. This could well be at the expense of the most innovative
and important waste minimisation sector in terms of the waste
hierarchy—SMEs and the voluntary and community sector.
Infrastructure desperately needs to be improved
and local networks of small enterprises set up to support a locally
based sustainable consumption and resource managed economy.
PRODUCER RESPONSIBILITY
REGULATION
We support the Government policy aim of the
use of the producer responsibility approach to ensure that businesses
take responsibility for the environmental impact of products that
they place on the market, and particularly once they become waste.
However we believe that producer responsibility measures should
be mandatory rather than voluntary.
We welcome the recent introduction of legislation
which incorporates some elements of producer responsibility requirements,
eg Packaging Directive and the WEEE and ELV Directives but we
believe that producer responsibility needs to be greatly extended
into new fields to capture other products and sectors. Producer
responsibility, for instance, should be extended to primary industries,
such as the agriculture, quarrying, mining, water and energy producers
since they produce amongst the greatest amounts of waste. Mining,
construction, agricultural and sewage industries cause the majority
of waste from raw resource usage and the majority of waste is
generated from manufacturing, construction and demolition and
mining activities (p34, Biffa, Future Perfect 2003).
Manufacturing, transport infrastructure and
building industries should also be targeted since it is at the
point of design that there is the greatest capacity to develop
product and process alternatives. With reference to the construction
and transport infrastructure industry, we welcome the development
of Site Waste Management Plans and the Code for Sustainable Homes
but consider that there is a need to introduce regulatory environmental
management measures. This would help improve sustainability performance,
including waste minimization and hazard reduction during the construction
stage, period of usage and demolition.
Producer distributors, retailers, vending operators,
fast food outlets and event organisers could also play a role
in producer responsibility through stewardship agreements.
We welcome the Government's aim of reducing
the overall cost of waste management by establishing incentives
for producers to consider the end of life waste management costs
however we feel that the focus should be on the prevention of
waste, and particularly hazardous waste. It is our view that the
Government's view of producer responsibility should be widened
to include a requirement on businesses to address and urgently
phase out the use of hazardous materials or processes. The aim
would be to prevent pollution and achieve zero discharge of persistent
or bio-accumulative substances.
We support the methods proposed by the Government
of identifying products and materials which have particularly
negative waste growth and environmental impacts being developed
for Sustainable Consumption and Production (SCP). (Securing the
Future, UK Gov Sustainable Development Strategy, March 2005) We
would suggest that this method could be used to identify products
and sectors requiring stronger producer responsibility guidance,
support or measures.
We believe that there is a need for better integration
of different policies affecting waste policy and key to this is
the development of linkages between waste and other government
policies. We therefore support the development of a Sustainable
Development Strategy. It is our view that producer responsibility
should require strategic partnerships to be developed with re-processors
and links developed to agriculture, water and energy. The producer
responsibility approach could create and optimise the development
of a more integrated recycling and recovery infrastructure and
could level the playing field amongst manufacturers and primary
industry operators who are adopting more sustainable and responsible
but, possibly, more costly practices eg eco design or organic
farming.
In our view, there are a number of producer
responsibility approaches which could be explored:
1. The producer deals with the liability
costs of the environmental damage caused by their product.
With this aim in mind, all new materials could
be required to undergo mandatory toxicity tests. Manufacturers
of materials could be required to take out insurance against any
environmental or health problems arising from new products over
a 50 year period.
2. The producer pays for the economic costs
of setting up the infrastructure needed to provide re-use, repair,
return, recycling or composting facilities to extend the "life"
of their products and packaging. The facilities could be on the
premises of distributors or traders.
The payment methods could be structured in such
a way as to reduce costs for companies which produce of durable,
repairable, easily recyclable or compostable products with minimal
packaging and to deter companies which do not adopt environmentally
responsible policies. Stewardship agreements could easily be linked
to producer responsibility measures.
3. The producer manages the physical products
and their packaging or the effects of the products and their packaging.
4. The producer adopts a take back ownership
system.
This approach would combine physical management
and economic payment for the product and its waste management.
5. The producer takes responsibility for
the product information.
Standardised systems would aid reliable information
feedback to customers and stakeholders.
LIFE CYCLE
ANALYSIS
We support the European Thematic Strategy recommendation
of a whole life-cycle approach to products, services and materials
to identify key environmental impacts from waste and resource
use.
In our view, the definition of "Life cycle"
impacts needs to be comprehensive. We consider that the life-cycle
approach should not simply be restricted to the production and
consumption phases of products and materials. One option might
be to adopt an entire life-cycle approach to producer responsibility
incorporating responsibility for waste generated from the extraction
of raw materials for the product to post consumption waste. The
Ecological Paradigm is an approach which examines the full impact
of any chemical product ie its feedstocks, by-products, wastes,
compound transformations as it breaks down throughout the life
cycle from extraction, synthesis, processing use and disposal
until all associated products and wastes are converted to chloride
ions. (Thornton, Pandora's Poisons, 2000) Life cycle analysis,
when used for long-term decision making, must reflect how each
stage of a life cycle is likely to change over time due, for example,
to waste composition changes etc.
We support the Government's proposals to focus
on developing data on the environmental impacts, including waste-related
impacts, of products across their life-cycle. We welcome proposals
for a review of Sustainable Consumption and Production evidence,
to identify gaps and priorities and new research requirements.
We agree with the methods outlined in the recent
England Waste Review 2007 report of identifying products and materials
which have particularly negative waste growth and environmental
impacts. We would add "durability of the product" to
the list of: "amounts of waste generated and amounts of hazardous
waste generated, projected growth rate of product sales and/or
product waste; weight and volume; hazardous waste content; use
of recyclates and used components; and ease of re-use and recycling."
HAZARDOUS MATERIALS
AND WASTE
We welcome the introduction of a Hazardous Waste
Forum and support the Government's aim to introduce a form of
producer responsibility to industrial sectors producing products
containing hazardous waste streams such as solvents used for industrial
cleaning or lubricating oils, garden pesticides and decorative
paints. However, we believe that the government should also target
pharmaceuticals products, cleaning agents, DIY chemicals, general
building products (eg insulation), car maintenance chemicals,
hygiene and beauty products, agricultural pesticides, growth hormones,
weed-killers, slurry, mining and quarrying wastes, ship-building
wastes, nuclear waste as well as ammunitions chemical and biological
weaponry.
We also welcome the introduction of the REACH regulations.
We support the key challenges set out by the
Government for hazardous waste management over the next 5 years:
— continue the trend for reductions
in arisings;
— provide treatment capacity for waste
diverted from landfill;
— meet the landfill waste acceptance
criteria; and
— tackle mis-management of hazardous
waste.
We would add a new target:
— To prevent or reduce the harmfulness
of materials, products or processes.
This target would support the European Framework
Directive on Waste which requires member states to encourage "the
prevention or reduction of waste production and its harmfulness."
It would also comply with the European Commission's thematic strategy
on the sustainable use and management of resources which will
include proposals to reach the Sixth Environmental Action Programme's
aim whereby: "the wastes are non-hazardous or at least present
only very low risks to the environment and human health."
The statistics on chemicals testing are shocking.
There are over 11,000 organo-chorines produced commercially and
thousands produced accidentally as by products. In 1984 there
were over 48,000 registered industrial chemicals, 3,300 pesticides,
8,600 food additives and 3,400 cosmetic ingredients in the US
alone! For industrial chemicals there have been no complete health
checks carried out and no data is available on 78% of the chemicals.
Information on accidental by products formed by the chlorine industry
is even less. (Thornton, Pandora's Poison, 2000). Even 100% post-consumer
recycling will manage only 2% of the total waste stream, without
addressing toxicity issues. In our view, all new chemicals should
automatically undergo toxicity testing.
In our view a stronger approach is required
where toxics have been identified to support the replacement and
phase out of those substances. Tighter regulation would help the
environment, encourage innovation and stimulate investment in
cleaner technologies as was found when CFC's were treated this
way under the Montreal Protocol.
In order to ensure that UK businesses are not
commercially disadvantaged by tighter regulation, we urge the
Government to consider legally binding international agreements
to restrict and phase out and eventually ban the manufacture,
generation, use, storage, discharge and disposal of persistent,
toxic bio-accumulative substances (similar to international agreements
on global warming and ozone depletion.) Priority could be set
according to the largest scale, most toxic chemicals and processes
based on current understanding of hazard posed. The introduction
of a rapid phase out process could then be introduced to encourage
the development of cleaner substitutes. This could then be followed
by a gradual phase out of other synthetics.
In the meantime, in order to encourage greater
producer responsibility, chemical companies should be forced to
face up to the risks associated with the release of these unknown
chemicals on to the environment without toxicity tests. Chemical
companies should be required to automatically undertake toxicity
tests on all new and hitherto un-tested chemicals before being
allowed to sell them on. They should be mandated to obtain insurance
for any chemicals they produce and they should not be allowed
to release the products to the public without insurance cover
for their potential health and environmental impacts.
With reference to household hazardous waste,
we welcome the introduction of guidance on good practice by the
National Household Hazardous Waste Forum and the Chartered Institute
of Waste Managers and are pleased that the Government recognises
the need for separate collections of household waste. Household
hazardous items requiring immediate attention might include: batteries,
oils, pharmaceuticals, paints, pesticides, cleaning fluids etc.
There is also an urgent need to develop hazardous
household waste plants for dealing with:
The banning of materials from landfill is another
approach which the Government should consider for deterring the
use of hazardous materials in products and for promoting recycling
and composting. However, materials bans from landfill must not
be undertaken without simultaneous measures to deter incineration
and maximize recycling of plastics, paper, cardboard, bio-degradable
material etc. We recognise that the banning of specific substances
from landfill will reduce the use of landfill. Landfill product
and substance bans have, for example, been successfully used in
Nova Scotia, Canada, to reduce landfill. In Nova Scotia the following
materials have been banned from being landfilled: biological waste
which has not been treated and neutralised, beverage containers,
corrugated cardboard, newsprint, lead-acid batteries, spent industrial
lubricants, used oil, paint, ethylene glycol (car anti-freeze),
some plastics, steel/tin containers, glass food containers, compostable
organic material from industrial, commercial, institutional and
residential sources. Nevertheless, it is our view that landfill
material bans should be accompanied by similar restrictions on
incineration. The Government's proposal to ban "all combustible
waste" is a key example of an integrated approach to landfill
bans. Many combustibles, obviously, have high calorific value
and would be extremely useful to the incineration industry but
could equally be a valuable resource to re-processors or composting
companies. Without an integrated policy approach, the banning
of all combustible waste from landfills could simply be used as
a regulatory carrot to promote incineration at the expense of
recycling and composting.
INFORMATION GAPS
The Government's acknowledgement that it does
not consider that there is sufficient information and evidence
on which to base a single prevention target for all waste or for
single major categories of waste points to the need for work to
be undertaken to address the issue. Research could be undertaken
to:
— Analyse who produces waste, where,
what the composition of waste is, why they produce it, whether
they recycle, compost or dispose of it and how their behaviour
and the waste composition might change under different circumstances.
— Identify resource exchange schemes, recycling
collection services, reprocessing, waste minimisation services
and products and suppliers.
A detailed analysis of waste content, waste
flows and current infrastructure is essential if the Government
and Regional Development Agencies are to: identify the likely
future composition of waste; scope the number of processing facilities
required and identify the infrastructure strengths and weaknesses
in each region. It will also help them to review the likely future
infrastructure, costs, regulatory options, charges and taxes and
fiscal remedies, procurement policies, contracts and funding requirements.
The New Technologies Fund has provided excellent
opportunities for research into capital based back-end technology
approaches to waste management however much more support needs
to be provided to establish the best approaches to front end elements
of the waste strategy:
— Waste minimisation (re-use and repair
schemes, producer responsibility measures)
— Price intervention measures and
— Support for the community sector
REGULATION
A firmer approach is required to promote waste
minimisation, recycling and composting. Where this has been used
(LATS/landfill tax/PRNs/incineration directive) this is when real
changes occur. A phased introduction of voluntary to manadotory
would allow for the considerations of business to be taken into
account.
The recent report by the Sustainable Consumption
Round Table (May 2006) "I will if you will" claims
that people want to adopt greener habits, but many believe individual
action is futile. The Government cannot therefore wait for businesses
and consumers to take voluntary measures to adopt green practices
and lifestyles. According to the Round Table report action stimulated
by regulation can be effective and go down well with the public.
People are generally quite happy with measures that bring positive
environmental results, even at some cost to themselves, so long
as those measures are applied fairly. This means that government
must take a lead in mandating and implementing regulatory, fiscal
and best practice initiatives.
We would urge the Government to introduce mandatory
"stewardship" requirements on producers and retailers,
traders and event organisers.
We believe that there is a need to design products
which generate less waste in use, result in less process and end-of-life
waste and do use any potentially hazardous materials in their
manufacture. However, we do recognise the need in exceptional
circumstances a restricted amount of pharmaceuticals to use hazardous
components.
We welcome the Government's assurance that it
is committed to promote eco-design as a mainstream element of
good design practice by bringing together expertise through a
new Sustainable Design Forum and the international Sustainable
Products Task Force, with support from the Market Transformation
Programme, Envirowise's Designtrack scheme and WRAP's Innovation
Fund.
We support the development of policies designed
to bring forward products, streams and services which are less
harmful to the environment through the work of the Market Transformation
Programme and the Environment Agency. We support the promotion
of less harmful products, systems and services although we would
prefer the use of enforcement practices rather than the introduction
of voluntary measures. It is therefore our view that the "consensus"
approach should be replaced with a mandatory requirement to reduce
waste and achieve more efficient resource use at the product design
phase.
We welcome the Eco-design for Energy-saving
Products Framework Directive.
We also welcome the two new policy instruments
(Site Waste Management Plans and the Code for Sustainable Homes)
to promote the adoption of more responsible environmental management
systems in the construction sector.
However, more producer responsibility measures
need to be introduced which result in a sustainable process whereby
any product, service or process leaves no unusable waste; uses
sustainable energy and replenishes the resource base in a closed
loop economy. This means designing out pollution and waste at
the start of the process through Clean Product Design and Clean
Production, and sensitive material selection. If there is a problem
at the end of the useful life of a product, process or service,
then the point at which the "problem" was introduced
must be re-designed so that the problem is no longer within the
process. Successful waste and pollution management can only be
achieved if the entire chain is considered.
There are a number of regulatory approaches
which could be used to promote producer responsibility practices:
— On-site recycling and composting
facilities requirements for large businesses
— Packaging take-back, re-fill or ease
of recycability or compostability requirements (especially for
transport packaging companies eg pallets, cardboard; secondary
packaging and primary packaging eg cans, jam jars etc);
— Minimum recycled or recovered material
content standards (especially in non-food packaging);
— Minimum energy, water and materials-efficiency
standards;
— Ease of dismantling requirements
(for re-use, repair, replacement or upgrading of parts);
— Disposal bans and restrictions;
— Materials bans and restrictions;
— Product bans and restrictions;
— Trade protection measures;
— Toxicity testing of new or untested
chemicals requirements
— Mandatory insurance cover for companies
which make chemicals to cover the costs of any potential health
and environmental impacts.
— Separate kerbside collection service
for hazardous household waste
— Separate kerbside collection service
for kitchen and garden waste
— Minimum 7 materials kerbside recycling
collection service
FISCAL ISSUES
Current production and waste management practices
are unsustainable. Therefore, we believe that the Government should
not be relying solely or too heavily on market forces and pricing
structures to develop sustainable industrial, business and householder
practices. Given that non-renewable resources will eventually
have to be phased out, the Government should be planning how to
implement that process in the least damaging manner.
We consider that more direct government intervention
in pricing policies can help to achieve environmental goals by
ensuring that prices reflect environmental impacts and discourage
behaviour that damages the environment. We therefore welcome the:
— Ending co-disposal of hazardous and
non hazardous wastes in landfill
— Local household incentive pilot schemes
— Landfill Allowance Trading Scheme
(LATS) and
— Tradable Packaging Waste Recovery
Notes (PRNs).
We support the use of economic instruments to
encourage behaviour change by manufacturers, traders, local authorities
and consumers but this needs to be combined with other regulatory,
educational, research and best practice policies.
A number of EU instruments are currently being
prepared which may impact on business behaviour and that these
may create price drivers to stimulate industry higher up the waste
hierarchy. Those EU instruments relate to:
— Producer Responsibility
— Traded Pollution Permits
— Energy Taxation or offsets
We welcome the broad aim of those proposals.
However, we do not believe that the tax and
economic instruments currently in use and proposed are sufficient
to stimulate moves towards industries higher up the waste hierarchy.
It is our view that the economic playing field must be rebalanced
and the hierarchy of profitability must match the environmental
hierarchy.
In our view, Government intervention could further
stimulate the following scenarios:
— The cost of waste disposal increasing
(due to inflation, fiscal and regulatory disincentives towards
landfill and incineration);
— The development and implementation
of best practice techniques of collection and sorting (due to
the introduction of waste minimisation and source separation targets
and the development of new "Green Academies" and other
educational initiatives.)
— Source separated kerbside collection
costs decreasing. (As these schemes become more efficient, costs
will reduce, markets will pick up, prices will rise and more people
will be enthused to take part in recycling. Investment in the
necessary infrastructure will be essential to develop local industries).
— The long-term costs of raw materials
rising particularly those subject to environmental constraints.
— The use of hazardous materials decreasing
and the increasing use of eco-design and producer responsibility
measures (due to fiscal and regulatory policies).
— The cost of reprocessed materials
reducing (due to increased materials supply and more supplier
outlets.)
— Innovative, industrial techniques
replacing artisan methods of disassembly and reprocessing with
the result of reduced costs (due to the increasing use of producer
responsibility measures).
— The development of a waste minimisation,
recycling and composting infrastructure that is locally based
and dominated by SM enterprises and voluntary and community organisations.
The SMEs and VCOs operating repair and re-use services could be
based in busy, convenient locations such as supermarkets thereby
encouraging customer behaviour change.
This could be promoted by the introduction of
a number of fiscal measures—environmental taxes, tax breaks
and exemptions, subsidy reform, grants and local tax rebates.
The aim would be to change price signals in the market place in
favour of more environmentally friendly products.
Economic instruments which could be considered
include:
— Virgin materials taxes;
— Removing subsidies for virgin materials;
— A requirement on all primary industries,
manufacturers and retailers to contribute to the cost of recycling
as well as disposal.
— Removal of tax advantages for industrial
processes that give rise to environmental degredation.
— Polluter taxes (eg energy, pollution,
emissions and/or discharges taxes) on all companies which produce
the most toxic classes of chemical eg chlorine and organo-chlorines,
SOx, NOx, CO2.
— Cutting the subsidies presently given
to incineration. The application of the Climate Change Levy, for
instance, to mixed waste energy from waste schemes would enable
practices higher up the waste hierarchy to compete on a more level
playing field.
— Tax rebates or subsidies to manufacturers
for eco-design/producer-responsibility schemes.
— Producer responsibility trading systems
linked to the National Industrial Symbiosis Programme on-line
database for tracking hazardous waste, composting, re-used and
recycled materials. The database could be greatly expanded and
processes introduced to link the system to producer responsibility
trading schemes.
— Grants for: business collaboration,
networking and academia work to support producer responsibility
processes.
— Grants for: re-use, re-manufacture
facilities (like the BREW fund)
— Disposable product taxes (for low
durability or short life products such as disposable nappies,
tampons, plastic bags). This would help more accurately reflect
the cost of disposal. Repair and reconditioning services are often
perceived as being expensive or inconvenient. Some products are
increasingly cheaper to dispose of than repair (eg watches and
shoes). Taxes on low durability, short life products could be
used to set up the infrastructure needed to support businesses
that repair and recondition products and improve customer access
to those services.
— Resource toxicity taxes eg on companies
that use toxic materials in products (eg heavy metals) where safer,
more sustainable materials are available.
— Repair, re-use or environmental performance
improvement allowances. Tradable allowance options of this kind
could be introduced to help the market deliver environmental outcomes
more efficiently.
— A sustainability levy applied to
all goods and services.
— Introducing a price guarantee scheme
for recycled materials to fund the build-up costs of seven stream
recycling (including food waste and hazardous waste).
— Grants for doorstep collection/delivery
re-use schemes. These might help to address the difficulties of
access to services.
— Deposit/refund systems (where consumers
have to pay high mandated deposits on non-refillable containers
but they can claim the deposit back for refillable containers);
— Recycling/re-use tax rebates for
retailers operating take-back schemes to meet storage costs.
— Business rebates for charities and
re-use community/voluntary organisations to contribute to the
high costs that this important sector is forced to undertake to
dispose of low quality donations that cannot be sold or recycled.
— Import tariffs on imported clothing
and shoes. The negative perceptions of second hand goods have
seriously impacted on the work of the charity sector because of
the cheapness of foreign imports particularly of new clothing
and shoes.
— Export tariffs on the sale of commingled
recyclates.
— Advanced disposal fees (paid when
the product is bought) imposed on products which are hazardous
and harder to dispose of eg fridges, pvc, batteries, electrical
goods, vehicles;
— Introducing a disposal tax that reflects
the environmental hierarchy by changing the current landfill tax
into a waste disposal tax that reflects the environmental costs
of different disposal options.
— A change in the landfill tax regulations
so that the 20% offsets are paid into a publicly-run waste minimisation/recycling
fund.
The tax revenue accrued could be used to pay
for:
— Building the infrastructure needed
to promote the re-use, repair, return, recycling or composting
facilities to extend the "life" of their products and
packaging. Re-use, repair, return, recycling and composting services
need to be convenient and locally based to promote the market
and make the service a more economic option for customers.
— Funding local authority, community
and voluntary sector schemes and the Strategy Unit.
— Promoting greater partnership work
between local authorities, community and voluntary groups and
small firms.
— Setting up a materials recovery fund.
— Recycling and waste minimisation
educational programmes.
— Setting up a transition fund for
workers and communities working in the most polluting industries
(eg chlorine and organo-chlorine industry based areas) to support
alternative economic development and training during the transition
phase to safer technologies.
Currently, the bulk of the financial costs,
penalties and risks associated with recycling, composting and
waste disposal of UK and imported goods are being borne by Council
Tax payers and Councils. The introduction of fiscal measures would
be the quickest method of encouraging businesses to review their
waste and resource management and purchasing practices. When waste
becomes a cost issue to business, waste minimization, recycling
and composting targets will also become greater priorities. Measures
need to be introduced which divert the costs of recycling or disposal
of household waste collection (particularly hazardous waste) away
from taxpayers to primary industries, manufacturers, distributors
and retail operators. In this way, those organisations dealing
with, and financially benefiting from, a product (from extraction
of raw materials to disposal) could be held accountable for their
role in creating waste and other environmental impacts. The producers
would be required to develop and implement waste (and other) environmental
management strategies to reduce the environmental impact of their
activities. In this context, producer responsibility would be
extended from manufacturing to cross all sectors and would include
a broader range of sustainability issues. It would also encourage
more responsible and integrated working practices.
In our view, other measures could also be introduced
targeting local authorities to promote the development of waste
strategies higher up the waste hierarchy. These could include:
— Funding to local authorities to set
up the infrastructure required to promote waste minimisation and
other policies high up the waste hierarchy
— A mandatory restriction on waste
contracts of five years. This would help create the flexibility
needed to enable local authorities to genuinely review their policies
at five yearly intervals. This would also allow local authorities
to honestly feed into the five year waste reviews by the Regional
Technical Advisory Bodies. In addition, it would enable developing
national and European policies and changes in waste management
policies to be more quickly enacted.
— Stop joint tendering of recycling
collection and refuse contracts to private companies (as these
threaten the ability of community groups to compete with national
companies.) Longer term integrated waste contracts shut out competition
and penalise community groups.
— More stringent green procurement
requirements on Government and public bodies to support environmentally
preferable products procurement systems. Government criteria for
awarding Local Authority Beacon status should include demonstrating
best practice in waste minimisation measures, buying recyclables
etc.
— End the commercial confidentiality
of waste contracts.
— Grants to support waste minimisation
practices within the local authority area with an emphasis on
support for local small businesses and other organisations.
— Greater flexibility for local authorities
to develop local environmental taxes and rebates. For example,
we support the mooted proposals to allow local authorities to
introduce variable charging for services to householders in a
form (eg general waste/recycling ratio) that supports the waste
hierarchy and supports the polluter pays principle. This would
raise awareness about the issues but would also have to be accompanied
with a major awareness raising campaign to explain why such local
fiscal measures were needed.
An Environmental Tax Commission could be set
up to examine the complex economic and regulatory impacts ahead
of and after their introduction. Such a commission could be responsible
for rebalancing the economic and sustainability playing field.
The Commission could administer transitional funds and assess
methods of "animating" change.
GREEN PROCUREMENT
AND PRACTICES
Local government procurement policies could
stimulate the market for green businesses. However, there is a
lack of knowledge about these issues amongst officers (as well
as the public, businesses, academic institutions and other networks.)
Government bodies need guidance on green procurement.. We therefore
very much welcome the Sustainable Procurement Task Force and plans
to achieve sustainable development through procurement practices
and the production of a National Action Plan.
There is a need to map out and promote best practice
in terms of:
— Green procurement policies;
— Waste minimisation practices; and
— Sustainable practices and environmental
management systems within businesses.
Green procurement could apply to building specifications,
lighting, energy, etc. This would help boost and support a stable
"green" market.
The Environment Agency green procurement policy
embraces a whole range of factors including the environmental
performance of the potential supplier. This might provide a good
starting point.
Punitive measures could be introduced to encourage
best practice by local authorities. Financial penalties could
be used against local authorities and government agencies that
fail to meet targets for waste management and green product procurement
to reduce waste and waste impacts and promote green manufacturers.
The development by local authorities of publicly
available lists of approved local suppliers with green/social
credentials might encourage suppliers to support businesses with
higher environmental management standards. If the list was publicly
available this could be an excellent resource for members of the
public and businesses. It would act as a further stimulant to
businesses and suppliers to become more responsible and would
additionally act as an excellent publicity outlet for exemplary
companies. The British Standard for environmental management systems
could be useful indicator for local authorities to use in relation
to identifying and supporting responsible suppliers and manufacturers.
MARKET DEVELOPMENT
Market development is very much linked to the
RDA aspect in the new WS2007. However, RDAs do not have a background
in that area and have extremely limited resources. Consideration
needs to be given to how RDAs will interact and communicate with
local authorities. This is certainly not a standard practice at
the moment.
In our view, if the development of markets for recycled
materials is to be accelerated, then systems need to be put in
place to ensure the promotion of:
— High quality of materials particularly
through increased and improved sorting
— Information and tracking systems
— A larger number of local materials
supplier outlets
— More recycling and reprocessing facilities
— Green procurement as standard practice
— Business education and training
— Fiscal incentives or disincentives
for businesses to recycle
If the full environmental and economic benefits
of composting and recycling are to be achieved then end markets
must exist. If end markets are to be developed and sustained,
then customers must have trust in the reliability and quality
of products they buy.
Standards are critical in order to reassure
those members of the public or reprocessors planning to use the
materials confidence in a consistent product. In our view, the
establishment of high standards for materials is critical if the
market for recycled goods, and, in particular, municipal compost
is to be developed.
Collection authorities therefore need to focus
on the collection of high quality materials. The Composting Association
has reported that a number of mixed waste plants abroad have failed
because of the poor quality of the material and particularly the
inability of processors to extract small glass fragments from
the material.
In our view, cleanliness is key to the production
of high quality materials. Separate collection (as opposed to
mixed waste collection which is subsequently sorted) is therefore
critical for the efficient collection of clean feedstock.
We note with some concern Defra's proposal that
"The main potential outlets (for biodegradable waste material)
include agricultural land, which depends on its value as a soil
improver and fertiliser, plus horticultural, landscaping or domestic
uses." The National Farmers' Union has stated that the potential
to use composted mixed municipal waste for agriculture is probably
limited. The NFU have concerns about contaminants getting into
the food chain. We agree with that view and do not believe that
agricultural, sewage and forest material should be mixed with
the composted elements of residual general waste. We have concerns
that once land where "soil improver" has been used has
been sold on it may inadvertently be used for food production.
We understand that compost had now been given
or is imminently due to be given new quality standards that enable
it now to be called a product not waste. We welcome this measure.
Composting by community organisations has been discouraged by
some waste regulations. We hope that this measure will encourage
greater composting by community organisations.
In our view, the current BVPI definition of
compost which incorporates the term "soil improver"
set standards that are so low that they bring the current BVPI
definition of compost into disrepute. In our view, there is a
need for clarity on the Best Value Performance Indicator for compost.
The definition of compost should be consistent across EU in order
to stimulate demand for compost and establish common quality standards
to help with acceptability. There should be a requirement that
local authorities undertake separate doorstep collections of organic
matter in order to prevent the sham recovery of waste materials.
"Soil improver" should therefore not classify as compost
under the BVPI definition for compost.
The NFU have pointed out the need for tracking
systems for compost and "traceability". That is a requirement
which we would support.
The statutory imposition of targets for commercial
organisations and local authorities would both help to secure
a constant supply of materials for recycling collection and reprocessing
organisations and increase the materials available.
Alternatively, export controls or tariffs might
be a means of maximising security of supply by restricting the
opportunities for exports of materials abroad.
The development of large-scale recycling will
also depend on the creation of regional-level processing and remanufacturing
plants that can draw on local materials and use existing infrastructure
as well as the connections between these producers and wider international
markets.
Facilities developing recycled materials are
widely distributed (relative to most primary materials) so there
are opportunities to develop the materials market.
This sets a challenge for the new regional development
agencies; they should work with local collection authorities to
build up local processing capacity to match the expanded supplies
of recycled materials, and with the private sector to expand the
recycling of wood, construction and demolition waste, tyres, commercial
organics etc.
For this to occur there is a need for education
and training of businesses and pecuniary incentives to recycle.
Green procurement practices must be promoted
to become the norm. We therefore welcome Defra's proposal to continue
to fund WRAP projects which stimulate domestic markets for recycled
materials and promote "green" procurement. We also support
the Sustainable Procurement Task Force's work to stimulate markets
through the development of innovative goods and services.
Investment in waste swap systems might be a
useful means of making the reprocessed materials market more accessible
to the wider public and businesses.
Regional economic policy could play a crucial
role in linking all these issues through the local economy to
the global economy.
The focus of waste minimisation, re-use and
repair activities need to focus on the work of the Voluntary Community
Sector and Small to Medium Enterprises. This is dealt with below.
VCSS AND
SMES
The waste minimisation sector is dominated by
small to medium sized enterprises and voluntary and community
organisations. This is likely to continue however the sector requires
major support if it is to expand and the barriers that are deterring
customers from using repair and re-use services and products need
to be urgently and effectively addressed.
We welcome the review of the WIP to consider how
to encourage the development of new providers of services and
facilities (including community sector).
However, it is our view that voluntary and community
waste organisations need much more support to enable them to compete
on a more even playing field with the private sector.
Currently, the cost of industrial technologies,
the size of plants and treatment means SMEs and the VCS are excluded
from PFI opportunities but if the focus was on services higher
up the waste hierarchy, especially waste minimisation, recycling
and composting then the opportunities for SMEs and VCSs could
be opened up.
The size of PFIs should be limited to discourage
capital intensive technology projects eg incineration/pyrolysis
or large materials reclamation facilities. PFIs should support
less capital waste minimisation and recycling/composting projects.
Local authority PFI projects should also have to fulfil various
general criteria eg promotion of sustainable development, contribution
to local cultural, social, health, safety, regeneration or educational
objectives and rigorous cost benefit analysis.
Local Authorities need to be encouraged to support
community and voluntary sector recycling organisations through
procurement packages that emphasize the additional training and
educational services that charities and re-use initiatives often
offer. In addition, we consider that the general emphasis of national,
regional and local regeneration work should be towards sustainable
resource management and sustainable consumption policies rather
than sustainable waste management.
Local authorities could encourage economic regeneration
through work with local SMEs and VCS businesses and Regional Development
Agencies. However in order to undertake such work local authorities
would require considerable additional resources to provide the
necessary support and investment.
Barriers to the procurement of services by local
authorities from the VCS and SME sector could be reduced by the
employment of regional waste liaison and business development
officers whose role could be to:
— improve co-ordination and development
of contractual and partnership opportunities, best practice, legal
advice, start-up support.
— Liaise between local authorities
and other organisations
— Address financial barriers by evaluating
and disseminating best practice and
— Improve future practice by supporting
research and innovation
STATUTORY PERFORMANCE
STANDARDS AND
TARGETS FOR
LOCAL AUTHORITIES
AND THE
LARGE BUSINESS
SECTOR
Waste reduction is at the top of the waste hierarchy
so the Government decision not to have targets for local authorities
for waste reduction is, in our opinion, more than an oversight.
This decision could result in another fridge mountain style of
crisis.
In our view, targets should reflect stated government
policies and the policies should be supported with regulatory,
educational, best practice, structural and fiscal initiatives.
Other countries do set national waste prevention targets. Scotland
has set targets for waste reduction and the EU is discussing including
waste reduction targets in new version next year
We suggest that the Government could produce
a waste reduction target for local authorities.
Another approach might be to develop repair/return/re-use
targets for local authorities. Materials reduction, return, repair
and re-use is higher up the waste hierarchy than recovery so these
targets should replace the current recovery target for collection
authorities.
Higher levels of divergence from landfill would
be more likely to be achieved and the clear message established
that waste is a resource if targets for the land-filling, re-use,
recycling, composting of commercial and industrial waste were
set. The introduction of business and industry re-use, recycling
and composting targets and targets for other sustainability issues
(such as those relating to energy and water use) would create
a more integrated approach to waste and sustainability policies.
They would stimulate greater awareness about sustainability issues—particularly
if they were accompanied by fiscal penalties or incentives. Targets
for large businesses would also create economies of scale that
could help to boost the recyclates market and general green economy.
Currently the Government acknowledges that it
"does not consider that there is sufficient information and
evidence on which to base a single prevention target for all waste
or for single major categories of waste" (page 21, paragraph
28, England Draft Waste Review) points to the need for work to
be undertaken to analyse who produces waste, where, what the composition
of waste is, why they produce it, and how it might change under
different circumstances.
The Government proposal that directors of large
private and quoted companies will be required to consider and
report on non-financial key performance indicators that are relevant
to their business, including information relating to environmental
matters, including waste" could provide a starting point
on which to obtain this basic information. The report Future Perfect
by Biffa (2003) suggested that targets for waste reduction and
recycling by businesses could include a statutory requirement
to provide environmental reporting data on waste management performance,
resource productivity, biodiversity etc in the annual reports
and accounts. If the data collection and reporting was carried
out in a standard format and automatically passed to the Environment
Agency, then the information gathered could provide the basis
for the development of national, regional and local waste strategy
policies and the assessment of waste infrastructure needs as well
as funding requirements. That is a measure we support and believe
would encourage transparency as well as greater corporate social
responsibility. If this work is to be carried out by the Environment
Agency, then the Agency will need considerable investment to enable
it to process the information quickly. Such work would provide
the basis for baseline waste prevention (and recycling) targets.
As a starting point, we welcome the proposal
that the Environment Agency will set a reduction in "waste
disposal target" for industries that it regulates.
Statutory waste reduction and materials repair,
return and re-use targets for manufacturers and other large companies
might be another method of promoting best practice amongst commercial
and industrial organisations—particularly manufacturers.
The introduction of statutory waste reduction, re-use/repair/return
targets and recycling and composting targets across all waste
sectors together with producer responsibility measures would also
push waste issues higher up the business agenda. Non-compliance
with the target could result in financial penalties or other measures.
Waste reduction targets for the biggest polluters could be monitored
by the Environment Agency.
Home and community composting of kitchen and
garden waste is the most sustainable form of composting yet it
is not classed as a category of composting. According to a recent
report by Dr Alan Knipe (May 2006, Lets Recycle) councils
could save millions of pounds a year by encouraging householders
to compost food waste at home, rather than splashing out on major
centralised treatment plants. "Based upon the 10% of UK households
using food waste digesters between 10 and 25 centralised treatment
facilities need not be constructed and there would be potential
cost savings of in excess of £20 million a year." The
House of Commons Select Committee proposed that local authorities
could estimate the amount of home composted waste by identifying
households with gardens and following the purchase of home composters
(from local authorities or other major suppliers). They recommended
that the government, Local Government Association, Composting
Association and Community Composting Network should find a method
for assessing the amount of home composting in the targets to
local authorities. There is a similar need to monitor composting
on allotments and other forms of community composting. The current
definition of compost creates a dis-incentive to local authorities
to promote home and community composting of kitchen and garden
waste. Therefore home and community composted waste should be
included in municipal composting figures.
The promotion of waste minimisation measures
is difficult where co-mingled wheelie bin systems in operation
using compaction lorries to crush the recyclates. The use of compaction
lorries for collecting products is not compatible with the aim
of restoring and repairing them. The mandatory use of box schemes
for the collection of waste minimisation or hazardous materials
would require local authorities to collect products for re-use
or repair such as tools, spectacles, stamps, cds, dvds, videos,
watches, etc or the reduced disposal of hazardous waste materials.
A further system of assessment might therefore be to introduce
a new "source separated materials collection" target
whereby local authorities could be required to increase the number
and range of materials collected by means of source separation
methods of collection. This might have to be individualised to
take into account the composition of the waste of each of the
local authorities. We would suggest a minimum number of 3 separate
waste streams (including compost and hazardous waste) but with
the aim of collecting a minimum of 7 waste streams.
A separation target would probably require a
mandatory increase in the number of waste streams that local authorities
are required to provide a kerbside collection service for. We
therefore consider that there is a need to increase the number
of recyclable items collection authorities are required to collect
from households. We suggest that the Household Waste Recycling
Act 2003 be amended to increase the number of items to at least
7.
EDUCATION
We support the Waste Minimisation Toolkit which
is a valuable aid in the development of data collection, measurement
tools and behaviour change approaches.
In our view, there are a number of barriers discouraging
members of the public from using services or buying products which
reduce waste or promote re-use, recycling or composting:
— Lack of knowledge about the environmental
impacts of actions they take and services and products they use.
— Lack of knowledge about what they
as individuals can do to minimize those impacts (eg using washable
nappies, Mooncups, composting waste).
— Lack of knowledge about best practice
products and services available locally (nappy laundry services,
community composting facilities, hire companies).
— Lack of knowledge about environmental
issues relating to individual products.
— Negative perceptions about re-use
schemes (eg share, lease, hire, repair, re-fill and return services)—in
particular facilities being inconvenient.
— Negative perceptions that second-hand
products, refurbished goods or items made from recycled materials
are poor quality and/or expensive.
— Lack of interest in or incentive
to change behaviour.
— Lack of access to information about
the above.
Lack of knowledge about the environmental impacts
of actions they take and services and products they use
We support the Environmental Action Fund's aim
to promote greater awareness on these issues.
The Eco and Enviro Schools schemes are other useful
tools for promoting responsible attitudes amongst young people
towards their environment and encouraging them to understand information
that is already available about products.
Both schemes warrant continued support.
Lack of knowledge about what they as individuals
can do to minimize those impacts
We support Environment Direct—a public
advice service on the impacts of different goods and services
and on how to make the most sustainable consumption choices. The
website is a superb resource.
We also support the Recycle Now and Smart Shopping
communication campaigns
These, too, are educational tools which should
be continued on a sustained basis.
Lack of knowledge about best practice products
and services available locally
Whilst we support national educational campaigns
such as the Recycle Now media advertising, the work of WRAP and
the retailers Re-usable Bag Campaign, we consider that it is essential
that educational campaigns should also be supported which promote
local schemes (both waste minimisation and recycling/composting).
In our view local campaigning works best because it can be adapted
to suit the particular characteristics of the audience and schemes
operating in the area.
In addition, educational campaigns should be aimed
at a wider audience (including hard to reach communities) and
be a sustained activity.
There is a need to map out and promote best
practice businesses and services to the public and other businesses,
academic institutions and other networks.
Policies promoting corporate social responsibility
and public access to information would also encourage companies
to demonstrate greater public accountability.
Other information to assist customers in extending
the life of their purchases could include:
— Information provided by operators
of convenience stores, vending and fast food outlets, organisers
of public and private events about the locations of local repair
centres, facilities to support re-use, recycling and composting.
This could be publicised on sales receipts (eg Nova Scotia), posters
or leaflets
— Recycling system endorsement labelling
(eg Germany's Green Dot system where consumers can leave the product
in designated bins and the product is guaranteed to be recycled);
Lack of knowledge about environmental issues relating
to individual products
We support the recent development by Defra of
a web site and a pocket sized guide to environmental labels in
order to help people understand the many different kinds of labels
already produced. We think this will be a useful public tool.
However, product information in different sectors
needs to be standardised. Information needs to be in a usable,
clear and honest form.
There is widespread mis-use of symbols, which
not only causes confusion to members of the public but can create
problems for reprocessing companies. The plastic recycling symbol,
for example, has widely been abused by packaging producers to
suggest to members of the public that the product could be easily
recycled. In fact, the wide range of plasticisers, softeners etc
that could form part of a container means that, whilst plastic
bottles often have a similar chemical make-up, yoghurt containers
and other packaging with the recycling symbol on do not and so
can not be easily recycled.
Lack of knowledge about environmental issues relating
to individual products
Information needs to support the customer in:
Potential labelling and symbols which would
support comparison on sustainable consumption indicators could
include:
— Seal-of-approval types of environmental
labelling
— Environmental information labelling
(energy efficiency, CFC use, recycled content or targets, recyclability,
expected lifetime)
— Ecological Foot printing or Environmental
Assessment Measures
— Product hazard and product durability
labelling (eg listings of the hazardous properties of the product
produced during its life cycle and their impacts)
— Lead by example schemes which identify
and promote businesses adopting best environmental practice.
Lack of interest in or incentive to change behaviour.
We support waste minimisation measures such
as behaviour change systems (especially positive incentive schemes).
Whilst we do support the right of local authorities
to introduce variable charging and other punitive behaviour change
systems with members of the public we think that the emphasis
should be on incentive schemes. It is our view that well promoted
incentive schemes can encourage greater public support for recycling
and waste minimisation and can help to reduce the need for punitive
measures.
In addition, there is an imperative to combine
incentive/disincentive work with simple to use, clearly promoted
and supported recycling, composting and waste minimisation schemes.
For example, box collection schemes are far easier to support
in terms of educating residents about contamination issues. When
contamination of wheelie bins takes place, the collection crews
are unable to see contamination at the bottom of the bins. Nor
are they able to simply leave a clear card explaining why particular
materials are not collected. Instead, local authorities have to
rely on the far more intimidating and negative method of employing
monitoring officers to identify bins with contamination and then
door knocking the householder to explain what they have "done
wrong".
Currently, members of the public are not encouraged
to use repair services, buy second-hand or re-conditioned products
or products that are made from recycled materials. Incentive schemes
combined with awareness raising campaigns could be used to educate
members of the public about the benefits of supporting sustainable
products and services and motivating them to take action. Washington
State's Get in the Loop scheme has proved successful and works
by combining advertising (about the importance of buying recycled
and telling them where they can buy recycled content products)
with free promotional material to participating retailers and
retailer promotion according to their level of participation in
the scheme. Incentive schemes and awareness raising campaigns
could be used in a similar way to motivate members of the public
to buy second hand or refurbished goods.
Behaviour change campaigns could also be used
to change trader, manufacturer or supplier behaviour eg low waste
packaging procurement policies.
Negative perceptions about re-use schemes—in
particular facilities being inconvenient.
There is an urgent need to explore measures
(particularly fiscal policies) to develop a waste minimisation
infrastructure dominated by small, locally based businesses. If
a sustainable consumption and resource management economy is to
be developed then issues of logistical inconvenience for reprocessors
and potential customers must be addressed. However, these policies
need to co-exist with educational campaigns to address issues
relating to negative perceptions and lack of knowledge.
Negative perceptions that second-hand products,
refurbished goods or items made from recycled materials are poor
quality and/or expensive
The UK reprocessing and manufacturing industries
compete on the world market by focussing on quality products.
This fact highlights the importance of encouraging the collection
of quality recyclates and composting materials and the imperative
of encouraging source separation methods of collection (rather
than co-mingled collection systems which suffer from high rates
of contamination). A move to targets focussing on source separation
and waste minimisation would assist in this regard.
Members of the public and reprocessors must have
faith in the products they buy. It is vital that standards are
improved.
Market development of quality goods needs to
be combined with promotional work. Promotional advertising needs
to be sustained to raise awareness and support for waste minimisation
activities, services and products, recycling and goods made from
recycled materials.
Lack of access to information
Gaps exist in public access to information about
the above-mentioned issues. In particular hard to reach groups
are often overlooked because of the expense of the communication
methods required to target those groups.
We welcome the Government's recognition of the importance
of local authorities translating information on services into
languages spoken by ethnic communities but in our experience local
authorities are reluctant to provide that service. The problem
relates to cost and the number of languages spoken (65 in Newcastle).
The situation is even worse as far as the provision
of information to individuals with disabilities is concerned especially
deaf individuals who may require the information in BSL format
and blind or partially sighted householders who may require formats
for their particular sight difficulties (eg cd, tape, large print,
Braille, daisy disc etc). This is despite the provisions of the
Disability Discrimination Act 1995.
Similar difficulties relate to providing information
(eg in tape format) to individuals who cannot read. In our opinion,
local authorities require additional support to target these hard
to reach groups.
Other information gaps include involvement of
customers and stakeholders. Attention needs to be paid to widening
access to information to:
— Members of the public in general;
We welcome the requirement on Directors of large
private and quoted companies to consider and report on non-financial
key performance indicators that are relevant to their business,
including environmental and waste issues.
Additional information to shareholders, customers
and other stakeholders could be supplied through performance data
relating to statutory targets for waste reduction and recycling.
Customers and shareholders could be more heavily involved in discussions
and decisions about sustainability issues.
BUSINESS SUPPORT
Businesses need support and easy and cheap access
to information, training, advice and funding to enable them to
make informed choices themselves.
We support the BREW funded work of Envirowise, the
Environment Agency's NetRegs, WRAP and the work of Business Links.
We also support the Environment Agency's pilot on-line internet
service "What do I do with my waste" and Net Regs guidance.
In addition, we welcome Defra's proposal that
it could help improve SME's access to appropriate recycling and
recovery services by a combination of:
— Advice and support under BREW, for
companies to improve their waste management and maximise resource
efficiency;
— Financial support under BREW for
organisations to set up recycling collection services for commercial
enterprises; and
— Placing recycling obligations on
some or all businesses and/or waste management companies.
We welcome the introduction of the National
Industrial Symbiosis Programme (matching one operator's waste
with another's raw materials needs) and believe that the principles
of industrial symbiosis provide significant potential for further
resource efficiencies. We believe that the database could be expanded
to contain information about distribution centres and waste resources.
This would be especially useful for manufacturers and organisations
wishing to exchange, sell or buy materials. The promotion of the
National Industrial Symbiosis Programme or a similar type of database
amongst the charity, refurbishment, repair and re-use sector might
prove useful. An on-line database for tracking hazardous waste,
composting, re-used and recycled materials could also be linked
to producer responsibility trading systems.
Businesses need clarity about which organisations
to approach for advice. Training and educational opportunities
for businesses, public and statutory professionals across all
sectors could be supported further in relation to green economies
with the establishment of:
— A new type of Green Academy. It could
be charged with developing organisational forms, knowledge and
skills relevant to zero waste and sustainable consumption. Its
curricula and priorities would be set by the needs of developing
environmental markets. Hence its research, teaching and skill
formation would be linked closely to ground level projects providing
learning opportunities to those in or outside employment. The
promotion of sustainable business practices including resource
efficiency and waste prevention and environmental education would
be part of the training of infrastructure development of professionals
and unskilled staff.
— The appointment of Zero Waste Advisers—some
recruited from leading waste minimisation, recycling and composting
projects overseas—to advise on waste reduction and recycling
schemes and projects. The group could be part of an international
network, promoting exchanges and part time attachments and linking
into practitioners' associations.
— A Sustainable Development Agency
incorporating a Zero Waste Agency to promote resource efficiency
and act as a guardian of public health.
— A national network of Regional Waste
Reduction and Recycling Coordinators. Work of this nature is invaluable
but needs funding.
— Best practice guidance (perhaps through
the use of a web site) on green procurement practices could be
made publicly available for use by central and local government,
their agencies and public bodies. Best practice guidance could
also be supplied on ways of supporting waste minimization, repair,
re-use, recycling and composting. This sort of information could
be of assistance to a wide range of individuals and organisations.
If businesses are to respond appropriately to
legislation then the Government and Environment Agency need to
provide clear and comprehensive guidance well in advance of regulatory
changes in order to allow sufficient time for investments. The
government currently uses a wide range of communications channels
to inform business about the requirements of legislation but we
consider that there need to be clearer points of reference for
business training and education particularly in relation to sustainable
business development.
There may be business opportunities for consultancies
to open up a niche market on advice on resource efficiency but
this may require some initial Government support.
BAN Waste
November 2007
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