Memorandum by The Chartered Institution
of Wastes Management
The Chartered Institution of Wastes Management
(CIWM) is the professional body which represents around 7,300
waste management professionals, predominantly in the UK but also
overseas. The CIWM sets the professional standards for individuals
working in the waste management industry and has various grades
of membership determined by education, qualification and experience.
EXECUTIVE SUMMARY
The Chartered Institution of Wastes Management
(CIWM) welcomes this opportunity to present evidence for an important
examination of the practice and future development of waste reduction
in the UK. In preparing this evidence the Institution has consulted
with experts members from several of its Special Interest Groups,
including its Waste and Resources, and Strategy Groups, and their
comments have incorporated into this response.
The Committee have posed a series of questions
as the basis for this inquiry and these are dealt with in detail
below. CIWM would however raise five main points as follows:
Terminology—the use of terms such as "minimisation",
"prevention" and "reduction" of wastes causes
confusion. CIWM would prefer concentration on waste reduction
in this inquiry, as this implies an active, managed and measurable
process using baseline data and on a time and/or product basis.
CIWM believes that waste prevention can only begin from a clear
understanding of resource use—including energy, water and
materials, and wastage. Lack of such understanding is a frequent
frustration to waste reduction, leaving minimisation or prevention
as poorly defined aspirational targets in many cases with poor
reporting of what is actually achieved.
Waste Strategies—This inquiry is timely
given the recent (May 2007) launch of the new Waste Strategy for
England and work on other UK national waste strategies. CIWM welcomes
the broader scope of these strategies which have in the past concentrated
on municipal waste and recycling. Whilst both are clearly important,
true resource efficiency and environment protection lies in action
on waste from all sectors, not just the less than 10 per cent
from municipal sources. The English waste strategy contains many
proposals to support waste reduction but this relies heavily on
further and more detailed work to be done. In turn, this relies
on strong co-ordination by Defra between various government departments
and with a broad range of stakeholders—all of whom have
a role in delivering the strategy in the real world. CIWM is happy
to commit to this work and the sustained co-ordination needed
to support it.
Resource Efficiency—waste prevention needs
to be viewed within the broader objective of whole life cycle
assessment of products and services. Our objective should be to
reduce energy, water and materials consumption in all stages of
design, manufacture, use and end-of-life management, not just
focus on cutting visible waste production at the production or
use stages. This requires data, information, tools and skills
to do and the practice of LCA needs support if it is to deliver
better design or products and processes in future.
Co-ordination—Government already supports
resource efficiency and waste reduction through a variety of bodies.
Whilst much good work is done through these bodies there is a
clear need for co-ordination and targeting of their efforts, especially
if changes are to be made at the SME end of the business spectrum.
Clear communications of the need for resource efficiency and the
business and environmental benefits is vital. Government also
must monitor the effectives of these measures closely as most
initiatives depend on cost saving opportunities for businesses.
If these do not bring about improvements needed in resource efficiency
more enforceable measures will need to be considered.
Priorities—this inquiry will inevitably
and rightly consider high visibility issues such as packaging,
carrier bags and disposable nappies. Whilst these are important
in their own right and in terms of their effectiveness in supporting
more general interest in resource efficiency, there are other
activities and waste streams that could have a much greater impact
in environmental and business terms including transport and food
wastes. Again, CIWM would urge a whole life cycle approach to
identifying future priorities for waste reduction / resource efficiency
action.
BETTER DESIGN
AND THE
USE OF
MATERIALS
What role can better design and materials play
in minimising the creation of waste?
Are there any barriers to how knowledge in this
area can best be translated and applied?
1) Better design and materials use can indeed
help prevent waste. However, the prime objective in design should
be to minimise the whole life cycle cost of products and services.
This should take into account all materials and energy used from
winning and provision of raw materials, the product's use and
its "end of life" management or disposal. The science
of life cycle analysis is still developing and data, tools and
skills to use them will be needed if we are to make justifiable
decisions on which designs are most sustainable, rather than producing
"least visible waste" designs.
2) Any public examination of waste prevention
will inevitably focus on products highly visible to the public—including
plastic carrier bags, disposable nappies and packaging. However,
in the pursuit of resource efficiency and least environmental
cost, rigorous analysis and concentration on more important issues
such as food waste (around 20 per cent by weight of household
waste) is needed.
3) Packaging and packaging waste reduction
remains important, however, in view of the materials and energy
used and because of the clear public interest. Changing public
attitudes and behaviours in issues such as packaging can lead
to altered awareness and performance in other areas with potentially
even greater environmental impact such as transport for example.
It is still important, however, to consider packaging from a full
environmental cost perspective. Packaging helps to reduce wastage
of the goods contained especially for delicate goods (including
electronics) or for foods which—when correctly packaged—suffer
fewer transport and handling losses and have longer shelf / kitchen
life. These savings have considerable energy and materials benefits
"upstream" in the production process. Optimising packaging
involves striking the right balance between product and health
protection and the materials and energy used.
4) Much work has already been done in reducing
packaging materials use, the weight of a glass milk bottle has
fallen from over 500 g to less than 250g. Two case studies on
PET light-weighting were reported in August 2007, where 500ml
bottles were reduced from 26g to 24g, without compromising the
brand shape of the bottle. There are, however, limits to light-weighting
packaging, especially if it no longer adequately protects the
contents or if it undermines reuse which does have an important
role in minimising the creation of waste.
5) Promoting design for reuse, remanufacturing
and recycling has been encouraged for many years and there are
more examples in consumer electronic goods and vehicles where
parts and materials are being recovered and reused.
6) EU and UK legislation already exists
to reduce the creation of hazardous wastes, in connection with
waste electrical and electronic equipment (Restriction of Hazardous
Substances—RoHS) and more widely through the Registration,
Evaluation, Authorisation and Restriction of Chemicals—REACH).
Other materials substitutions are also possible—eg using
cardboard to reduce the need for polystyrene. This helps simplify
the wastes and supports high quality secondary material recycling—but
may have complex impacts in terms of the energy costs of transport
for example. Careful assessment of whole life cycle costs is needed
in such cases.
7) CIWM would support continued but better
co-ordinated integration between the various product and Resource
Knowledge Transfer Networks which should be encouraged to facilitate
knowledge transfer between different industry sectors. Better
interaction is needed between those responsible for design, manufacture
and supply of products and the waste and resources management
sector—both in terms of better design for end of life and
to ensure this industry supplies secondary materials back into
the market of the right quality.
What factors influence the use of materials? In
what way do considerations of sustainability feature in the selection
of most commonly used materials?
8) CIWM believes the primary driver is cost
for most products. Other measures are needed to drive manufacturers
and designers to increase their use of secondary materials. Our
sector is focused on reprocessing waste materials to a standard
where it can be placed on to the market—where there is confidence
to buy and use. Manufacturers need to be confident that it is
good clean quality material going to market; this can be underpinned
by recycled content drivers. An example of a positive one is recycled
content of newsprint paper.
9) Primarily cost, other considerations
are product design (including regulations concerning food containment),
design criteria (look, durability, strength), client requirement
and storage criteria (vapour barriers, temperature).
10) Moving away from virgin materials will
depend upon recovered materials meeting product standards, quality
and cost. This is difficult to maintain in a mixed and variable
commodity world where prices are volatile.
To what extent do product designers and engineers
take into account the availability and the end of life impacts
of raw materials?
11) There is a historic tendency to focus
on raw material specifications when selecting resources, and there
is a need for engineers, in particular, to be guided towards fit-for-purpose
product specifications as an alternative approach. The long term
strategy should be to ensure that life cycle analysis of materials
used is included in design and engineering.
12) Although there are one or two good examples
of designing for end-of-life CIWM believes that awareness and
understanding of materials and end-of-life impacts is generally
low.
What impact does the development of new materials
have on design? How much interaction is there between material
scientists and designers?
13) New materials do have an influence on
design and designers and materials scientists will interact. However,
CIWM believes that there is not enough interaction with the resource
and waste management industry; eg biodegradable/degradable plastics
are a new material being used by designers and engineers without
full consideration of the potential impact on the quality of composts
through cross contamination by the different types of plastic.
14) Research and Design on new materials
needs to feed through to scientists and designers.
Can better designed products offset the increase
in consumption?
15) In part, this is constrained by unfettered
consumer behaviour. Consumers will be influenced by fashion and
new designs, and will not necessarily purchase items which last
longer, reducing consumption. Much consumption, it could be argued,
is driven by the need to replace items that have built in obsolescence.
The greater availability of higher levels of disposable income
in the UK exacerbates this tendency.
16) The paradigm of reducing packaging and
long lasting products may in fact not be the best solution. Reuse
schemes for eg bottles and plastic containers cannot be implemented
if the bottles are too fragile, also longer lasting white goods
may in fact have more harmful environmental impacts in the use
of energy than replacements. Manufacturers are now seriously considering
the leasing of items like cars and white goods so that consumers
can have the best environmental product and that producers exercise
their responsibility by getting the materials back for recycling
and also component parts for reuse.
17) Another issue is whether increased consumerism
is being promoted by marketing campaigns based on environmental
and/or ethical issues, especially where such products replace
those already owned by consumers.
18) CIWM is not aware of any research but
it would seem reasonable to assume that individuals who purchase
environmentally and/or socially more responsible products are
less likely so simply dispose of products they already own by
dumping them. They are more likely to try and ensure their reuse—whether
on E-bay, at car boot sales, through Freecycle networks etc—or
leave in garages or lofts.
Are there any other gaps in knowledge and how
are they being addressed?
19) The Environment Agency and Defra are
currently working on a series of Quality Protocols, to determine
when wastes cease to be wastes and become acceptable as secondary
raw materials, based on fit-for-purpose product specifications.
The first Quality Protocol, for compost, was published in March
2007.
20) This has led to the waste and resource
management industry approaching the manufacturing industries to
ask them to consider whether the materials they discard can be
reprocessed into secondary materials and at what quality.
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?
How central is sustainable design to business
thinking? What initiatives are in place to encourage this and
are they meeting business needs?
21) There is growing evidence of businesses
reducing materials and energy use / wastage as a part of their
corporate social responsibility, for example in the construction
and retail sectors. Supply chain pressure exerted through these
"early movers" will be an increasingly important driver
for resource efficiency. However, for most businesses, waste prevention
is still driven through opportunities to reduce costs or to comply
with legislation.
22) An example of a purely voluntary arrangement
is the Courtauld Commitment by large retailers focused on packaging.
This could be a powerful way to make change and to influence buyer
behaviour, but previous voluntary arrangements in other areas,
eg farm plastics, have not been effective. Time available to make
important changes in materials management is short and Government
must monitor the effectiveness of voluntary arrangements closely
and be prepared to replace them with enforceable alternatives
if necessary. Arrangements such as the Courtauld Commitment will
not be appropriate for smaller businesses unless it is heavily
adapted and supported for their needs. Another example of voluntary
practise is the objective in parts of the construction sector
to drive for zero waste to landfill much earlier (2010) than proposed
in the draft sustainable construction strategy (2020). Such a
commitment will need to be supported by better materials separation,
management and reporting services through waste and resource managers.
23) The mandatory introduction of Site Waste
Management Plans in 2008 for most construction sites (suggested
project threshold £250,000) is an innovative approach that
CIWM believes will lead to waste prevention. This could be applied
to other industry sectors through mandatory reporting on environmental
performance by businesses, including wastes and energy / resources
use.
24) Rapid development of waste legislation—mostly
led by the EU—has improved standards and driven the cost
of responsible wastes and resources management upwards in the
UK. Examples include the Landfill Directive, changes to hazardous
waste management and the Landfill Tax. Higher costs and business
responsibilities for waste help drive waste prevention as businesses
strive to ensure compliance and to control costs—especially
where previously the low cost of waste disposal has discouraged
concentration on waste as an important business issue.
25) Business awareness of policy and legislation
relating to waste is often still low however. Awareness of specific
producer responsibility legislation is better understood by obligated
businesses, but more general responsibilities such as the waste
Duty of Care are poorly understood. Government must ensure that
strategies and legislation for waste and resources are backed
by clear and sustained communications programmes—one of
the benefits being support for better waste prevention. The Environment
Agency's NetRegs web-based tool helps provide authoritative legislation
and policy information to businesses, but this depends on the
businesses themselves to recognising they need the information.
More active measures are needed to communicate with businesses.
26) Businesses often rely on their waste
service provider to help them to be compliant. This is an important
area for added value service by the waste sector, and will become
more so as waste legislation becomes more complex and onerous
in future. CIWM believes that waste managers should increasingly
be in a position to advise customers on waste compliance and on
the types and quantities of wastes that businesses produce in
the future.
27) Formal Producer Responsibilities have
been introduced for a series of product types: vehicles, packaging,
electronics and batteries. Their focus is on end-of-life recycling
and recovery, but businesses' obligations to meet these responsibilities
are a force behind product design to reduce material use and improve
recyclability. In packaging, setting targets for recycling recovery
have led to increased tonnages being collected. The parallel Essential
Requirements legislation (1998 as amended in 2003) focusing on
design has been less rigorously enforced and there have been few
examples of prosecution for offences.
28) Government supports waste prevention
and better design initiatives for businesses through the Business
Resource Efficiency and Waste (BREW) programme. This programme
distributes Landfill Tax—derived funds to a range of delivery
bodies including:
— WRAP—the waste and resources
action programme.
— NISP—the National Industrial
Symbiosis Programme.
— The Environment Agency.
29) These programmes promote resource efficiency
in process or product design through cost savings for businesses.
Although there is a recognised need to help SMEs to benefit from
these opportunities, they remain the hardest "targets"
to reach. It is right that landfill tax paid by businesses is
used to help those businesses to be more competitive and more
resource efficient in the process. CIWM wishes to see Government
maintain their commitment to this programme and not reduce its
funding after the current year. More targeting of BREW resources
through delivery bodies is needed to reach smaller organisations
rather than larger ones who are aware of the need for and advantages
of waste prevention and better design. Much simpler communication
is also needed to guide businesses to sources of information and
support. The number of initiatives driven locally regionally and
nationally can overlap and confuse businesses. There is considerable
scope for better co-ordination and communication between business
support bodies working in this area—BREW funded or otherwise.
CIWM would like to see one BREW funded body take the lead in this
area.
What other measures can promote a focus on waste
reduction among businesses?
30) Prompting "extended" producer
responsibility to cover business practice and that of its supply
chain companies.
31) Promote the concept for businesses to
consider their product at the end of its life in order to understand
its impact from design to disposal. Therefore encouraging whole
life cycle analyses.
What lessons can business learn from international
experience?
CIWM declines to comment.
GOVERNMENT POLICY
What is and should be the role of Government in
addressing the issue of waste reduction?
32) Promoting the issue of waste reduction
in its own estate, and that of public organisations in general.
This should also cover procurement, in terms of products containing
recyclable materials. SEPA has gone further in this respect by
specifying minimum percentages for aggregates and paper.
33) CIWM believes it is the Government's
job to reallocate landfill tax monies via initiatives like BREW
to support better use of resources and business performance. However,
CIWM does not want to see a reduction in the proportion of tax
being paid, being used in this way.
34) CIWM believes that the Government should
continue to support initiatives like NISP to stimulate the secondary
materials markets, protocol and standards.
35) Specific Government policies could include:
— Promote the role of waste reduction
as part of Corporate Social Responsibility (introducing mandatory
reporting guidelines if voluntary measures are unsuccessful).
— Restriction of certain materials
to allow the simplification of reprocessing at the end-of-life.
— Consider specific bans on the manufacture
of short-life products (eg the decision to promote long-life/low-energy
light bulbs and phase out traditional light bulbs).
— Explores taxes (and/or bans) on selected
items including virgin raw materials.
— Regulation over unsolicited mail.
— Early confirmation that the new landfill
tax escalator of £8 per tonne with effect from April 2008
will continue beyond 2010-11.
— Consideration if the landfill tax
on inert is too low.
— Further bans on landfilling certain
wastes from all sectors and not just municipal solid wastes.
— Proactive communication strategies
across all sectors.
— Economic incentives to generate and
use energy from renewable sources including the recovery of energy
from residual wastes.
How does Government policy link up with European
strategies and action plans?
CIWM declines to comment.
What lessons can be learnt from other countries—within
the EU and globally?
36) CIWM believes other EU member states
are much further advanced in waste management infrastructure to
recover valuable materials and energy from their wastes. As early
input to Defra's waste strategy review and development CIWM commissioned
a report to examine the reasons for these differences.[3]
CONSUMER BEHAVIOUR
How can better product design be used to effect
a change in consumption patterns and behaviour?
CIWM declines to comment.
What role do marketing strategies play in influencing
more sustainable design?
CIWM declines to comment.
Are there any gaps in knowledge in this area?
CIWM declines to comment.
SKILLS
How is sustainable design integrated into the
design syllabus?
37) CIWM does not know, but supports the
inclusion of sustainable design into the design syllabus. CIWM
would be delighted to be involved and offers its help in any way
appropriate to make this happen. The Centre for Sustainable Design
have worked hard at this and have had a marked influence at Government
and regional level but their influence at industry level has been
limited.
To what extent are considerations of sustainable
waste reduction part of broader industrial training courses?
38) CIWM has been running Waste Awareness
Certificate (WAC) courses for a number of years, to the resource
and waste management industry as well as many other sectors. As
the WAC courses have grown CIWM has realised the need for sector
specific versions. WAC plus Construction has been developed and
delivered and work is ongoing with WAC plus Healthcare.[4]
39) It is very important that considerations
of sustainable resource use and waste production are also included
in course materials for design, engineering and marketing students
and business qualifications in general.
October 2007
3 Please follow this link for Delivering Key Waste
Management Infrastructure: Lessons Learned from Europe. November
2005 http://www.ciwm.co.uk/mediastore/FILES/12134.pdf Back
4
See http://www.ciwm.co.uk/pm/389 Back
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