COVER STORY
benefits of doing so) than it was with questioning whether separate collections for these materials were needed at all. The reason behind this discussion is that separate collection is only required under the regulations where it is Technically, Environmentally and Economically Practicable (TEEP). The absence of clear direction from Defra as to what this meant and their decision to leave it to the industry to define, created a significant amount of uncertainty and diverted attention from delivery.
Linked to this lack of clarity over TEEP was an equal lack of commitment from the authorities as to how the regulations would be enforced. There was also a general acceptance that the regulatory bodies were far too under resourced to really have any teeth when it came to enforcement. This lack of resources meant that a light touch self-regulation approach was the only real option available. Whilst it is quite possible that I may have missed it, I don’t recall any action being taken to address non- compliance since the regulations were introduced.
Another challenge around the introduction of the new regulations was the general lack of communication. Whilst the waste sector was in the main, aware of its obligations and worked hard to communicate, they would certainly have benefited from more support in broadening the communication to businesses. This would have had the obvious benefit of helping businesses understand what service they should expect from their contractor whilst also helping to create a ‘pull effect.’ We would see businesses demanding that their contractor was providing a compliant service, irrespective of where the ultimate responsibility lay.
The issue of responsibility is another interesting point. In contrast to the Scottish Zero Waste Regulations, where responsibility for compliance sits with the waste producer, the English Regulations see this responsibility placed with the waste collector. Whilst there are perhaps pros and cons for both models I believe that by placing the legal responsibility with the customer
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regulatory compliance with increased costs mean that it is perhaps unsurprising that we continue to see such a high number of non-compliant or inefficient collections. The reality is, however, that these regulations are really no more than the formalisation of good practice when it comes to managing your waste. In fact, if you were to outline a basic common sense waste strategy to someone new to the sector you would almost certainly advise removal of recyclable material if for no other reason than every tonne recycled avoids £82 in landfill tax alone. Furthermore, you are helping ensure that as much material as possible is recovered. These valuable secondary resources can then be incorporated back in to more sustainable supply chains for the future.
“EVERY TONNE
RECYCLED AVOIDS £82 IN LANDFILL TAX ALONE.”
you are in effect creating a demand. The market will naturally respond to this demand by supplying a service to meet it.
As big a challenge as compliance itself is, the question is whether the focus on it is always a helpful one. The problem is that there is often a significant difference between a compliant service and an optimum service for the waste producer. So simply providing an additional service to a customer, whilst meaning the obligation is met, may not be the optimal service either commercially or environmentally. There is little doubt a more collaborative approach would in most cases be more efficient.
These challenges, coupled with the fact that most people associate
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Indeed to further improve the quality of the secondary resources we can recover, I would like to have seen the regulations go further to include the separate collection of food. From the 1st January 2016 businesses in Scotland that produce more than 5kg a week of food waste must segregate it from their general waste and present it for separate collection. The hope is that this will have a significant impact in reducing landfill emissions and recyclate contamination whilst also increasing the amount of food waste that can be used in processes such as anaerobic digestion to produce sustainable energy.
Helistrat’s position has always been that we should embrace the new regulations and we work hard to ensure that all our contractors provide a compliant service as a bare minimum. Ultimately we believe the regulations could and should be a great catalyst for change. They present a great opportunity for those responsible for managing waste to intervene, review their recycling and resource management systems and ensure that they are optimised both in terms of cost control and environmental performance.
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