To most of us keen recyclers and Zero Waste advocates, the BC Recycling Regulation is a bit of a mystery. Perhaps I should not generalize, but until recently the Recycling Regulation did not influence or participate in my day to day life as CEO of Urban Impact Recycling. But in May of 2011, this changed. With one pen stroke government was to become part of my everyday business life. In May of 2011 the addition of “Schedule 5” to the Recycling Regulation transferred the responsibility for dealing with residentially produced Printed Paper & Packaging from local governments to the producers. With this pen stroke, another layer of bureaucracy and regulation was born in BC. Transferring responsibility for residential Printed Paper and Packaging has pushed producers together under one roof to discharge their obligations, although if they are so inclined they can deal with their material on their own. Coming together means and requires them to come up with a common Plan. In addition to the Plan, they must come up with performance indicators so that in future years the Plan, its diversion and performance can be evaluated and publicized.
I fundamentally agree with the concept that a producer should come up with reasonable and real performance indicators. It is a great strategy to allow industry to set reasonable and real evaluation of themselves. Presumably this approach will create buy-in from the producers and force them to perform at a minimum level. I would, however, like to point out a problem with this approach. A “Plan” for diversion is an integrated system. In the case of Printed Paper and Packaging it will require the producers to understand a reverse supply chain. Producers (other than perhaps the Walmarts of the world) are not familiar with reverse supply chains; their talent is getting a product to market, not getting it out of the waste stream.
Let me try to explain the issue with an analogy: It is like asking a commercial Truck Driver to do maintenance on his vehicle, when his specialty is operating a large vehicle, navigating city streets, and efficiently completing a route, all in a safe manner. In my example, I would argue that asking a Truck Driver to operate the vehicle and be a specialized mechanic for the vehicle is not a reasonable expectation, nor is it a sustainable formula for success. In the case of Printed Paper and Packaging, a well-established, integrated and efficient system exists in BC today. Why would producers want to re-invent the wheel and challenge what the real commercial market has already provided? Why should they be asked to become reverse supply chain specialists?
Back to Performance Criteria, the Recycling Regulation Guide, produced by the BC Ministry of Environment, states a number of items that a plan must address: • Were stakeholders were consulted adequately? • Is the collection system accessible to the consumer? • What are the recovery rates?, how is the plan doing in diverting more waste? • Are consumers aware about the program?, do they know what to do with their product? • What is the cost of the system? • Have they successfully managed the environmental impacts of their program? • How will they resolve disputes in the system?
In addition to the above, I also heard additional Performance Criteria presented at the Coast Waste Management Association conference in November 2012: • How are the products managed (“Life Cycle Management”)? • How does the Plan encourage alignment with the Pollution Prevention Hierarchy?
The Ministry also requires producers to include specific Performance Indictors under each of the above categories. Selected indicators must be: • representative of performance • easily communicated and understood by stakeholders • based on accessible, reliable and accurate data that is verifiable by a third party • cost effective: the costs and collection effort associated with selected performance measures, should be proportionate to the informational value they provide • consistent over time and facilitate fair cross-program comparisons by using generally accepted measurement methodology
Although I think that the Recycling Regulation Guide gives a good baseline and some good suggestions with respect to criteria and the rationale behind them, it unfortunately does not do a good job outlining or stating the consequences that it wants to avoid. In addition, the criteria do not include many important specifics such as measuring greenhouse gases and other environmental costs, or maintaining/bolstering the Green Economy and Jobs in BC. Jobs may not technically be the mandate of the Ministry of Environment, but I think a negative effect on jobs resulting from this program would not and should not be tolerated politically by the BC government. Written by Nicole Stefenelli, CEO of Urban Impact: http://urbanimpact.com/ on her blog on key industry issues...