Memorandum by Essex County Council
SUMMARY
It is the view of Essex County Council that
if there is to be a true commitment to the waste hierarchy which
clearly places reduction and reuse above recycling, then there
must to be a much greater public and industry focus on waste prevention
and minimisation over the long term.
Adoption of waste prevention and minimisation
activities by the public is, in the main, low as generally these
activities are, from the public perspective, time consuming, out
of their control and require significant changes in lifestyle
which are often seen as reducing the quality of their life (ie
having to go without). As a result of the viewpoint of the public
it is often difficult for local authorities to significantly influence
behaviour particularly when most activity is focused on enabling
and encouraging.
Adoption of waste prevention and minimisation
activities by industry seems to vary greatly; taking place only
where a clear financial or competitive advantage can be demonstrated.
If waste management is going to shift significantly
up the waste hierarchy then a more interventionist approach is
required to tackle the issues at source, primarily focusing on
producers, manufacturers and retailers. This should focus on all
stages along the product supply chain to ensure waste generation
is minimised at the design/manufacture phase of products, and
greater steps are taken to remove the use of unnecessary packaging.
With regard to the public, the issue of reduction
and reuse needs to be escalated at a national level. Public awareness
of the issues, problems, opportunities and costs needs to be raised
as a way of stimulating individual action. The ultimate goal should
be that generating high levels of waste is seen as socially unacceptable
behaviour and taking active steps to reduce waste is normalised.
For this goal to be achieved it is likely that even after tackling
waste at source and "pricking" social conscience, further
actions will need to be taken of a punitive nature. We would support
any activities which provided greater information to the consumer
on the environmental impact of their purchasing choices and would
highlight the success of energy efficiency labelling on electrical
goods as a model which could be replicated for wasteful products.
Making changes to the current pricing framework
for household waste to allow for variable charging for household
waste will enable local authorities to take the ultimate actions
against those generating excessive waste; this approach will also
fully embrace the polluter pays principle. This approach is prevalent
in the water, gas and electricity industries and Essex believes
that the option to introduce direct financial linkages for waste
need to be available to local authorities.
Charging for waste in this manner has focused
the attention of commercial organisations to reduce waste and
there is no reason to doubt a similar effect will be seen on domestic
waste providing all steps are taken to enable householders to
prevent and minimise waste (eg through home composting) and maximise
recycling prior to introducing punitive measures.
BETTER DESIGN
AND USE
OF MATERIALS
What role can better design and material play
in minimising the creation of waste?
If waste reduction is going to be effectively
tackled it is essential that there is a shift away from end of
pipe solutions. The public generally feel that waste avoidance
is out of their control as products are not designed with waste
avoidance as a primary focus. The over use of packaging and the
disposable nature of many products results in high levels of waste
which the public feel is an inevitable result of consumerism.
Opportunities to "design-out" waste
within the end products as well as within manufacturing process
must be taken by designers and manufacturers if overall waste
arisings are to be reduced. This will require a shift in mindset
for manufacturers as well as support.
The work of WRAP within the area of supporting
manufacturers and retail buyers must continue. The work being
undertaken by WRAP to promote the use of alternative materials
and the light-weighting of packaging has started to have an impact
within the industry. This work needs to be expanded and promoted
more widely. The promotion of actions taken by manufacturers and/or
retailers can then form part of the purchasing decision made by
the public.
Great strides have been made to reduce the quantity
of collected waste through the introduction and promotion of home
composting as a waste reduction tool. Since 2000 Essex has distributed
and supported the use of over 95,000 compost bins (in partnership
with WRAP from 2005). The use of bins by almost a fifth of Essex
households has undoubtedly reduced the quantity of material collected
by Essex waste authorities. This at-source treatment of waste
provides a ready opportunity for manufacturers to focus on the
use of biodegradable packaging/materials which can readily be
disposed of within home composting units.
Essex County Council is taking a lead in addressing
the challenges around production of waste created by development
pressures in the region. Policies and guidance are in place which
will influence the design process to take account of the waste
arising from developments.
The Urban Place Supplement (UPS), a companion
document to the Essex Design Guide which provides guidance on
the layout and design of housing and mixed use development, sets
out criteria for new development that will minimise waste, reduce
pollution and promotes sustainable construction. The UPS challenges
designers to:
— have regard to the reuse of materials
that may already exist on site;
— consider the advantages of off site
pre-assembled, prefabricated or standard sized components, which
can reduce the amount waste produced during the construction process;
— choose materials which have good
weathering properties that are durable and capable of being recycled.
This will thus minimising waste during the life time of the building;
and
— designing deconstruction into properties
enable further reuse of materials.
These principle factors are equally transferable
to the manufacture/retail sector.
The requirement for some developers to have
Site Waste Plans has played a major role in increasing knowledge
within the construction industry. This should be extended to ensure
waste reduction in terms of the choice of materials is also factored
into the design of such developments.
Can better designed products offset the increase
in consumption?
Improvements to the design of products can undoubtedly
lead to a reduction in consumption by the public particularly
when design improvements are coupled with increased durability
and reusability. However for impact to be maximised, this approach
needs to be undertaken in a climate of increased awareness and
public consciousness so that there is a direct link between the
waste reduction design elements of a product and the purchasing
decisions of the consumer.
Greater availability of information to the public
on the material efficiency of products (through a similar eco-labeling
approach as that adopted for product energy usage) when coupled
with the normalisation of waste reduction/prevention will assist
the public in making informed purchasing choices.
In targeting the end product, it should not
be ignored that significant levels of resource consumption take
place in the development and manufacture of products, and therefore
improvements to the design of products must be extended to the
manufacturing process. The impact of increasing material resource
efficiency within the manufacture of products will have a much
greater impact on total waste arisings within the UK than focusing
solely on the end product.
The activities of Envirowise, WRAP and the National
Industrial Symbiosis Programme (NISP) have introduced the concept
of resource efficiency and co-operation between differing business
sectors as a means of improving performance and reducing consumption
by businesses. These activities must be continued to ensure that
the concept of waste reduction and increased resource efficiency
become central to the ethos of manufactures. This concept has
been extended on a regional and local scale with both the public
and SMEs through the promotion of waste exchanges.
Are there any gaps in knowledge and how are they
being addressed?
Essex has had some experience in this area in
relation to the promotion of the ethos of the UPS. This has demonstrated
that in a rapidly changing physical and policy environment everyone
is on a steep learning curve, including those in the development
industry and local authorities.
The Essex Design Initiative learning programme
aims to disseminate information, increase the knowledge and skills
to developers/agents/local authority planners around the issues
contained within the UPS. Included in this programme there are
seminars which address waste management and minimisation. It is
however a challenge to capture the small builder carrying out
small scale development [less than 10 units] which accounts for
87 per cent of the planning applications in Essex for new housing,
however these developments only account for about 1 per cent of
new housing stock.
BUSINESS FRAMEWORK
Does the current policy, regulatory and legal
framework support and incentivise the development of better, more
sustainable products and processes? How is the framework communicated
to businesses and what is the level of awareness and understanding
among businesses?
The producer responsibility regulatory framework
has gone some way in focusing the manufacturing and retail sector
on producing and specifying more sustainable products and improved
processes which minimise waste arisings. Essex would support an
approach which increases the scope of producer responsibility
to other products and allows for organisations to meet their obligations
through the sale/design of reusability, longevity and upgradability
into products.
The key legislative tool available to local
government to tackle excessive waste resulting from products placed
on the market is The Packaging (Essential Requirements) Regulations
2003. This does enable Trading Standards (Weights and Measures
Authorities) to take action against those that place on the market
goods which use excessive packaging. Although supportive of this
legislation the low number of successful actions taken against
those responsible for putting over-packaged products on the market
highlights the inherent difficulty in applying these regulations.
Essex would wish to see a simplification of these regulations
to enable greater applicability and the extension for enforcement
to the Environment Agency. This would enable a much greater use
of the regulations against national and international manufacturers.
Current national policies and regulations support
the development of sustainable solutions but generally central
government legislation does not demand the use of sustainable
products, for example, the Government's Code for Sustainable Homes
that sets the minimum standard for the environmental impact of
materials in house building requires elements of construction
to meet the BRE Green Guide 2006 rating of at least D, however
Code compliance is currently voluntary. It is instead left to
individual authorities, agencies, landowners, clients to require
the use of more sustainable products/processes.
The number of enquires handled by Essex County
Council would seem to indicate that the level of understanding,
particularly amongst small and medium sized enterprises, is low.
It is essential that all business sectors understand and adopt
the necessary measures to ensure legal compliance and the adoption
of good practice.
What other measures can promote a focus on waste
reduction among business?
In addition to the use of punitive fiscal and/or
legislative measures the key aspect which will encourage the adoption
of waste reduction measures by business is if this can be demonstrated
to improve efficiency or provide a competitive advantage.
The role of Envirowise and NISP and similar
local/regional agencies have positively impacted on the way in
which business use material resources providing them with the
opportunity to reduce costs, increase efficiency and thus allowing
them to compete more effectively within the market place. The
work of such organisations must therefore be encouraged and allowed
to continue.
The opportunities for business to have a competitive
advantage through improved resource efficiency can also be driven
by public expectations. If the inefficient use of resources is
seen as socially unacceptable by the general public then those
organisations that can demonstrate a good track record in this
area will have greater opportunity to prosper.
GOVERNMENT POLICY
What is and should be the role of Government in
addressing the issues of waste reduction?
If waste management is going to shift significantly
up the waste hierarchy then there needs to be an increased government
focus on waste reduction. Essex CC feels that a more interventionist
approach is required to tackle the issues at source, primarily
focusing on producers, manufacturers and retailers. This should
focus on all stages along the product supply chain to ensure waste
generation is minimised at the design/manufacture phase of products
and greater steps are taken to remove the use of unnecessary packaging.
Government intervention can take a number of
forms including the use of punitive measures. These could take
the form of an extension producer responsibility regulation to
tackle single use/disposable items such as razors, cameras or
nappies where a reusable or longer lived alternative exists, thus
ensuring the true cost of these items is reflected in the retail
price. A greater requirement for repairability/upgradability to
be designed into products or the introduction of a minimum lifespan/warranty
period for products could be introduced.
Government also needs to take a lead in demonstrating
what can be achieved to reduce waste by putting waste reduction
into practice within its own operations. The adoption of government
departmental targets for waste reduction along side those for
recycling should be adopted to demonstrate real commitment to
the waste hierarchy.
It is only once active measures have been taken
to design waste out of products that either national or local
government can expect the public to adopt greater waste avoidance
within the home. Despite the almost universal acceptance and understanding
of the need to recycle there still seems to be widespread ignorance
amongst the public with regard to the concept of waste reduction
or the need to take personal responsibility.
A key role of government needs to be to develop
and fund an overarching national waste prevention message over
a long period. Such a message must tap into the public consciousness
and make use of the drivers which influence public behaviour in
this area, many of which may not be associated with environmental
concerns. As with all campaigns aimed at changing behaviour it
is essential that these are carried out over an extended period
and properly resourced. WRAP have demonstrated significant success
in developing the national recycling campaign which has been almost
universally adopted by local authorities.
In raising the public understanding and acceptance
of waste reduction it is essential that Government takes the necessary
actions to enable the public to make informed choices. This could
take the form of extending the eco-labelling approach to highlight
the efficiency of products with regard to the use of material
within the final product and during the manufacture. Such an approach
has clearly resulted in an increase in the uptake of energy efficient
products and there is no reason to assume this could not be replicated
for waste reduction.
Although the role of reuse is often seen as
delaying the entry of material into the waste stream and therefore
not true reduction, its role in waste management and the wider
social benefits should not be ignored. The third sector play an
active role in the provision of reuse activities resulting in
significant social and economic spin-off benefits. A requirement
to incorporate repairability into the design of products would
stimulate this area of activity.
The use of punitive measures targeted at the
public disposing of waste can only be used once reasonable effort
has been taken to "design-out" inefficient material
use in products, provide the public with alternative purchasing
options. Essex County Council supports the recent consultation
on the introduction of measures to enable Waste Authorities to
operate differential charging mechanisms for waste collection
and disposal. It is however the view of Essex that for this to
work effectively there must be the flexibility for waste to be
treated like utility and that charges must be set at a level to
influence behaviour.
CONSUMER BEHAVIOUR
How can better design be used to effect a change
in consumption patterns and behaviour?
Better design and the use of materials without
fiscal measures or actions which limit consumer choice will only
influence consumer behaviour if there is a public groundswell
against inefficient use of materials. As previously stated the
ultimate goal should be to ensure high waste generation whether
it is by the public or manufacturers is seen as socially unacceptable.
This will only be achieved through an effective, continuous and
high profile national public awareness campaign.
A shift in public opinion against inefficient
resource use and high levels of waste generation together with
improved product information on resource efficiency will assist
in shifting public consumption patterns. This will be further
enhanced when coupled with fiscal measures such as those detailed
previously.
Are there any gaps in this area?
Significant gaps exist in knowledge relating
to the impact of socio-demographics on consumption and therefore
the triggers which influence purchasing choices and behavioural
shift. If waste reduction is to be achieved successfully the ideal
approach is that this is driven through public demand rather than
fiscal or legislation, although these have a part to play. Such
a shift in public opinion can only be achieved through a true
understanding of what motivates the public to minimise waste.
22 October 2007
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