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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...

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