|
The Sustainable Management of Wastes from Business and Public Sector Organisations in Scotland
Response of the Scottish Environmental Services Association
The Scottish Environmental Services Association (SESA) is the sectoral trade association representing the UK's managers of waste and secondary resources. SESA’s Members seek to align economic and environmental sustainability through delivering compliance with relevant EU waste and environment legislation.
SESA strongly advocates the principle of an overarching strategy for collection, analysis and dissemination of waste data.
SESA believes the Scottish Executive and SEPA should increase its efforts to promote sustainable waste management across all levels of business. Activity should go beyond raising waste awareness, and include providing the necessary drivers to change waste producer behaviour.
A properly funded and targeted national initiative is required to ensure a range of inter-related drivers are in place to change practice and support sustainable markets for recycled material. Under-pinning these drivers should be regulations which are consistent and risk-based in nature and applied across the whole sector. These regulations should be supported by a stronger and more effective penalty regime.
Targets should be set to encourage the transition towards more sustainable waste management practice with an efficient method of monitoring and reporting performance.
SESA’s specific comments are set out below
Question 1: SEPA and the Scottish Executive are carrying out a review of the National Best Practice Projects (NBPPs). We would welcome views on whether the approach taken (considering specific waste streams and making recommendations on best practice) remains appropriate. Consultees are invited to comment on:
(a) the overall approach taken in relation to NBPPs, and whether this remains appropriate.
(b) waste streams/industrial sectors that might benefit from the NBPP approach.
(c) the aims and outputs that should be laid down and achieved when an NBPP project is established.
While it is sensible to target specific waste streams, SEPA and the Scottish Executive should ensure the timing of the collection of baseline data and the subsequent production of good practice is aligned with the production of regulations which associated with a particular waste stream. This will ensure best practice guidance is available prior to production of the regulations.
The collection of data as part of the baseline review should, where possible, make use of existing data returns of waste arising. Duplication of requests for information places onerous demands on waste producers.
Question 2:
a) Do consultees consider there is more that SEPA and the Scottish Executive could do to collect better data in relation to the amount of commercial and industrial waste arisings?
b) If yes, what? (options could include further surveys; collecting more detailed information on waste types and introducing duties on waste producers to report on the waste types and quantities produced.)
Yes: data collection and reporting requirements should be strengthened to ensure consistent reporting across all businesses. The waste management industry already reports huge quantities of data to regulators, and any increase in reporting must be accompanied by greater effort by those regulators in collating, analysing and publishing accurate Scotland-wide data. SEPA needs also to recognise the varying ability of companies to report (i.e. IT and electronic returns) and for its part needs to ensure it has the systems in place to receive, collate and report the data. SEPA should ensure that duplicate requests for data are minimised and eliminated.
SESA would like to see a centrally coordinated approach to data collection. The success of the proposed approach will depend ultimately on the data that is being requested. It is crucial that data requirements have been carefully considered and are fit for their intended purpose.
Question 3:
a) Are the potential barriers for SMEs achieving more sustainable waste management, outlined in paragraph 2.04 above, accurate?
b) Are there any additional barriers?
c) What action can be taken to tackle these barriers?
Waste producers, particularly SMEs appear to be largely ignorant of even their basic legal duties regarding management of waste. The Environment Agency in England and Wales has found that 85% of SMEs were not aware of their obligations under Duty of Care and there is no evidence to show that the situation in Scotland is any better. Huge efforts are needed by SEPA and the Scottish Executive to ensure that appropriate messages are communicated to SMEs.
In addition to the barriers set out, both waste management costs and penalties for non-compliance are too low to register sufficiently in day-to-day business decisions. Whilst costs are likely to rise in future years, price alone cannot be relied on to increase awareness, and a coordinated national campaign is required.
Question 4:
a) Can Local Authorities do more to provide advice to businesses on available local services for recycling and waste prevention?
b) Are businesses aware of any particular examples that could be used as a model of good practice? If yes, please specify.
Evidence from the Environment Agency in England has shown that private sector operators are ideally positioned to provide advice to their customers, and the Executive and SEPA should work with SESA Members to support this important role that operators play.
It is not within the core remit of local authorities to provide advice to business and SESA suggestes that this function is best provided centrally by recognised national organisations, supported by private sector operators.
Question 5:
a) Could Trade Associations do more to encourage businesses to address waste management?
b) If yes, what? This may involve a signposting role rather than developing their own guidance.
Trade Associations have a duty to encourage their Members to work within the law and fulfil their obligations under the duty of care to ensure their waste is managed legally through the appropriate recovery/recycling/disposal channels. Trade Associations should promote best practice in waste management, and can publicise the services carried out by private sector waste managers.
Question 6:
a) Is it practical for businesses to share collection and storage facilities to encourage recycling?
b) Please detail any issues in relation to businesses using recycling centres (civic amenity sites).
Sharing of facilities for the storage and collection of wastes from a number of businesses could address the issue of on-site storage, as space can be a constraint for many business, particularly SMEs. However, arrangements would clearly need to comply with waste management regulations. There is a danger that, without proper monitoring and controls, producers might be tempted to offload their waste without completing the necessary paper work to ensure a waste management audit trail (duty of care) is in place.
However, there is greater scope for encouraging businesses to recycle rather than simply combining storage and collection facilities. A more effective method to encourage recycling is to ensure sustainable markets exist for the end products. This, for example, could be achieved through the setting of targets for recyclate materials in the public procurement process.
Though adequate collection facilities is an important consideration, the behaviour of businesses will ultimately be driven by economics. Therefore, creating sustainable markets for recyclates could prove to be the driver for encouraging the proper infrastructure and properly licensed collection facilities.
Question 7:
a) Should the Scottish Executive, SEPA or other agencies do more to raise awareness of waste issues amongst larger companies?
b) Are any of the following points relevant to your industry?
i) Whether key decision makers in companies are aware of the costs of waste.
ii) Whether further training would be helpful.
iii) Ensuring that decision makers consider all parts of the manufacturing process and not just some of the process.
iv) Over-ordering of materials.
v) Ability of companies to spend time on waste issues, given the other pressures on business.
vi) Other (please specify)
The requirement to provide assistance and practical advice should not just be aimed at SMEs. Sustainable waste management practices should be widely promoted to businesses, of all sizes, throughout the sector.
However, SESA seeks stronger measures than just raising waste awareness amongst companies. While education is one means of promoting more sustainable waste management practices there needs to be a stronger drive to change waste producer behaviour. There needs to be clear and consistent waste producer responsibility regulations in place and backed up by an effective, strong and consistent penalty regime. The threat of penalties is likely to be a far greater incentive to drive a change in behaviour than education alone.
Question 8:
a) Is there any more the Scottish Executive and SEPA or other agencies could be doing in relation to the provision of infrastructure to deal with commercial and industrial waste?
b) If yes, what?
c) Is there any more the Scottish Executive and SEPA or other Government agencies could be doing to take account of potential synergies between domestic waste and commercial and industrial waste?
d) If yes, what?
The Scottish Executive, SEPA and other agencies should concentrate on ensuring that a robust framework is in place to provide a level playing field for private sector operators to provide waste treatment facilities.
SEPA must obtain and report accurate waste arising data for commercial and industrial waste streams. With this baseline data, the Scottish Executive would better placed to plan for the recovery and recycling of commercial and industrial wastes and advise local authorities (through the planning system) where such facilities are likely to be required.
Environmental regulation defines the market in waste management: without the consistent enforcement of clear rules, operators will not have the certainty required to invest in new infrastructure to recycle, recover and treat waste. SEPA should ensure that regulation are clear, consistent, risk-based, outcome focussed, and work with the grain of markets. The Environment Agency in England and Wales has set out its approach to modernising regulation and is preparing a “sector” plan to help the transformation: a similar approach in Scotland would be welcomed.
Investment in waste recycling facilities is an essential component of delivering the National Waste Strategy and enabling increased recycling and recovery of business waste.
However, conflicts between Area Waste Plans and local authority development plans have resulted in an ineffective planning system which often fails to deliver the necessary waste management infrastructure.
The waste planning system should be improved by increasing efficiency, certainty and coordination. For instance:
- preparing model planning policies for local authorities
- encouraging environmental business planning zones
- introducing limited permitted development rights for minor, non-controversial developments that do not have any impact beyond the site boundary and which will quickly improve the management and performance of a facility.
Question 9:
a) Do consultees consider that more should be done to promote site waste management plans?
b) if yes, what?
c) Could planning conditions be used by local authorities to require developers to produce construction and demolition waste prevention and management plans for developments above a specified (financial) threshold?
d) If yes, what should this threshold be?
SESA strongly advocates plans and systems which promote sustainable and legal waste management practices.
Large-scale developments should be required to have a site waste management plan in place. SESA would welcome an opportunity to contribute to the development of a statutory code of practice. Such a code of practice could, amongst other things, refer developers to a directory of responsible waste management companies and the services they deliver.
Implementation of a site waste management plan would need to be closely monitored which has implications for the regulatory body. For example, the enforcement agency would need to ensure that waste generated was being managed in accordance with the plan and may need to provide guidance on issues that were not identified during the development of the site waste management plan.
Question 10:
a) Do consultees consider targets could be introduced, after further consultation?
b) If so, what areas could be covered and what targets could be set?
c) Would the public sector be a possible candidate for targets?
SESA’s Members represent an essential component to achieving a more resource efficient society by returning more materials and energy contained in waste back to the productive economy.
Given the need to develop markets in recycled materials, SESA believes that challenging targets should be set and that performance against these should be used as indicators of sustainable consumption and production.
Targets have already been set for many businesses under producer responsibility regulations (e.g. packaging waste and WEEE) and there has been success in the establishment of targets under voluntary schemes (newsprint industry). However, provided the regulations are timely, fair and consistent, SESA would like to see the scope of target setting under producer responsibility widened to cover as many waste producers and waste streams as possible.
SESA strongly advocates the setting of targets to promote more sustainable waste practices. The setting of targets for recyclate content in public sector procurement is one such proposal where SESA sees considerable merit. The scope of target setting should be as wide as possible to include the Scottish Executive, its agencies, local authorities, registered social landlords, non-departmental government bodies and other bodies providing a service put out to tender.
Question 11:
a) Are voluntary agreements a way of reducing waste arisings; or reducing waste going to landfill or encouraging recycling?
b) If so, to which sectors could these be extended and what would be the main areas which such an agreement should cover?
c) Please give details of any industry that would consider entering into voluntary agreements with the Executive on sustainable waste management.
The effectiveness of voluntary agreements has been demonstrated through successful recycling in the newspaper industry. Another voluntary means of reducing waste would be to encourage businesses and public sector to report on waste arisings and progress towards recycling within annual statements. Making this data available in the public domain would provide an incentive for responsible b to reduce waste arisings and increase rates of recycling.
Question 12:
a) Do consultees consider that the promotion of waste minimisation within the PPC regime should be strengthened?
b) If yes, how?
Current provision towards waste minimisation in the PPC regime appear appropriate.
Question 13: Do consultees believe that it is feasible to introduce bans on the landfill disposal of certain materials? If so, would consultees please identify the materials for which a ban could be imposed.
There will always be a need for landfill as a legitimate and sustainable option to manage residual waste. However there may be scope for exploring the progressive reduction in landfilling of certain materials where this can be demonstrated to be economically and environmentally justifiable.
However, proposed bans must be accompanied by adequate advanced notice along with clear guidance on how banned material should be treated. This will allow the industry to adapt and provide the necessary facilities to recover and treat wastes.
|
