Memorandum by the Institution of Chemical
Engineers (IChemE)
ABOUT ICHEME
IChemE is the hub for chemical, biochemical
and process engineering professionals worldwide. The heart of
the process community, IChemE promotes competence and a commitment
to best practice, advancing the science and practice of chemical
engineering for the benefit of society and supporting the professional
development of an international membership exceeding 27,000. The
Institution has the role of a learned society, publishing books,
journals and training packages and organising events and courses
including the successful Hazards Symposium Series and the 12th
International Symposium on Safety and Loss Prevention in the Process
Industries in May 2007.
BACKGROUND
1) This response was prepared by a group
of senior professional chemical engineers in Institution of Chemical
Engineers (IChemE) membership with extensive experience of chemical
process operations, sustainable development and environmental
protection. IChemE gratefully acknowledges the leadership role
played by Malcolm Wilkinson in preparing this consultation response.
2) This output is representative of the
broad consensus of opinion within the group and is published as
IChemE's formal response to the House of Lords Science and Technology
Committee inquiry into waste reduction.
INTRODUCTION
3) Perhaps the first point to make about
waste is the problem of gaining a quantitative and up to date
understanding of who produces what and where it goes. This is
due to the difficulty of interpreting the plethora of data produced
by different sources and the fact that the latest published data
is from 2004. This of course pre-dates the 2005 Hazardous Waste
Directive and only covers the first reporting period (2001-03)
of the Landfill Directive.
4) What is clear though is that the tonnage
of waste produced in the UK continues to increase year on year
and this is particularly true for municipal waste. Conversely
the total waste produced by the chemical industry, and the proportion
classed as hazardous, is on a downward trend and the amount of
hazardous material recycled, by energy recovery or reprocessing,
is increasing. Whilst this is encouraging, there is still much
that can be done to further reduce this waste stream which, after
all, represents a financial loss to the industry not only due
to the costs of disposal but also because of the raw material
and processing costs it inherently contains.
BETTER DESIGN
AND THE
USE OF
MATERIALS
5) Better design and use of materials should
focus on two aspects, namely the product itself and the packaging
it is sold in.
6) Better product design must focus on commercial
"afterlife". Often the end of a product's life is prematurely
determined by technological or stylistic obsolescence rather than
fundamental performance or quality failure. If commercial "afterlife"
is incorporated into the design strategy the value added to the
molecules, products, processes and systems can be recovered and
reused at their highest value level.
7) Materials selection should be based on
maximising the use of renewable substances; evaluating the inherent
nature of all selected materials and energy inputs to ensure they
are as benign as possible; and minimising material diversity in
the product to make it easier at the end of its life to disassemble
for reuse and recycle.
8) End of life considerations have become
a serious design requirement in some industries mainly as a result
of legislation such as the End of Life Vehicle Directive and the
Waste Electrical and Electronic Equipment Directive. The design
principle here is that highly complex, high entropy substances
should be preserved for reuse whilst substances of minimal complexity
are favoured for recycling or disposal. End of life design decisions
should be based on the invested material and energy and subsequent
complexity across all design scales.
9) Process design should be based on preventing
waste rather than treating or cleaning it up after it is formed;
maximising mass, energy, space and time efficiency; and not building
in unnecessary capacity or capability.
10) Packaging design is an undervalued activity.
The vast majority of today's domestic waste is packaging and much
of it, invariably plastic, is both unnecessary and persistent
in the environment. Manufacturers and retailers need to place
much greater emphasis on minimising packaging, providing facilities
for return and choosing materials that can be recycled or are
bio-degradable.
11) Considerations of sustainability remain
well down the list of factors impacting on the selection of materials
and the design of products and processes in most organisations.
The 12 Principles of Green Engineering[1]
provide a common language for the conversations that must take
place between designers of molecules, materials, components, products
and complex systems. Whilst there are examples of the application
of many of these principles in isolation, designers have not systematically
integrated them into a holistic design approach and this remains
the challenge.
BUSINESS FRAMEWORK
12) The current policy on sustainable development
is fragmented with inconsistent buy-in across government departments;
it is not clear and as such has not been well communicated. The
Government has consistently sent out confusing messages either
by contradicting policy (Fuel Duty Escalator) or saying one thing
and doing another (Climate Change Bill v airport expansion). Consequently
the regulatory and legal framework is also fragmented and whilst
it has led to improvements in some industries it has in no way
begun to make sustainable design central to business thinking.
13) The Technology Strategy Board has designated
Sustainable Production and Consumption and Advanced Materials
as key technology areas which both play to the sustainability
agenda but the available funding limits the number of research
projects and hence the level of industrial involvement. The extent
to which the R&D tax credit scheme has further contributed
to developments in this area is not clear.
14) The long running Envirowise programme
has supported business in reducing waste, and the establishment
of the Waste & Resources Action Programme (WRAP) and the National
Industrial Symbiosis Programme (NISP) has provided business with
some focus on recycling and finding innovative uses for waste
material. These practical initiatives are particularly relevant
for SMEs. They tend to focus on immediate operational issues and
whilst they solve problems they rarely tackle root cause and have
low impact on strategic thinking.
15) The Chemistry Leadership Council published
a "Vision for the Sustainable Production and Use of Chemicals"
in 2005 but uptake of the broad principles enshrined therein has
to date not been widespread. The process industry is highly regulated
and aspects of the Integrated Pollution Prevention & Control
(IPPC) legislation promote continuous improvement and therefore
incrementally move towards more sustainable operations. Registration,
Evaluation and Authorisation of Chemicals (REACH) legislation
will also encourage product substitution and again is a move forward.
Nonetheless substantial technology innovation is required to really
advance industry to a new level of performance and the risk/reward
profile has not to date been viewed conducive to significant action.
GOVERNMENT POLICY
16) Waste has been the Government's bête
noire; an area of grandiose strategy statements and no policy
follow through; hence our position as third worst in Europe for
material going to landfill. It has consistently dragged its feet
in implementing EU Directives and even when implementing them
has failed to provide resources to do so effectively. Exemplar
countries, such as Denmark and the Netherlands, should be used
as sources of best practice.
17) Significant progress on waste minimisation
and sustainable development requires innovation both technological
and organisational. Government should provide the environment
to encourage such activity and where necessary the legislation
to drive it. This requires a holistic policy approach laying out
clear objectives and timescales which businesses can use to strategically
plan their operations. Innovation requires support that goes beyond
the research phase and into development; in the process industry
specifically current financial incentives stop short of the point
at which the risk/reward profile becomes acceptable.
SKILLS
18) Sustainable development is part of the
core chemical engineering degree curriculum required for Institution
of Chemical Engineers course accreditation. Two university chemical
engineering departments, Oxford and Newcastle, have benefited
from Royal Academy of Engineering funded chairs in sustainable
development and the teaching material they have generated is available
across the community. There are now cadres of young chemical engineers
beginning to emerge from universities with an understanding of
sustainable development and experience of applying the concepts
in their design projects.
October 2007
1 (Anastas, P; Zimmerman, J. Environmental Science
& Technology, 2003, 37, 94A-101A) Back
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