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Muck Becomes Brass

18 September 2008

A growing demand for increased environmental awareness in all sectors is changing the face of manufacturing waste management. Driven by legislation and public opinion, FMs in this sector face challenges, as Dr. Nick Williams explains

UK BUSINESSES HAVE FACED A SHARP INCREASE in the demand to be more environmentally aware in recent years, with pressure coming from both official sources and consumers. Environmental legislation, financial squeezes and public opinion are all forcing companies to become much more accountable for the volumes of waste and pollutants they produce, and for the environmental damage their commercial and industrial operations cause.

In fact, the ‘producer responsibility’ and ‘polluter pays’ principles enshrined in modern waste management laws mean businesses can no longer afford to be lax about the amount of waste they produce, and what they do with it. For the beleaguered FM, legal developments such as the updated EU Landfill Directive, the Packaging Waste Regulations 2007 and the WEEE Directive 2007 have dramatically changed the level and types of compliance responsibility heaped on their shoulders, and for none more so than the FM in manufacturing.

The law which first shifted the balance of responsibility away from the waste disposal industry and towards the waste producer is the Environmental Protection Act 1990 (EPA). Well established at nearly 18 years old, the EPA places a legally binding ‘Duty of Care’ upon all waste producers, to ensure their waste is handled and disposed of ‘appropriately’ from production right up to final disposal - or from ‘cradle to grave’. This set the trend for subsequent waste legislation and environmental guidance, which effectively builds upon the EPA and defines what is ‘appropriate’ for different types of waste.

In the case of hazardous waste for example, the category into which various manufacturing wastes fall, the required process becomes more complex still. Under the Hazardous Waste (England and Wales) Regulations 2005, a business can generate as little as 200kg of hazardous waste per annum, to be required to register as a hazardous waste producer with the Environment Agency, who will then monitor compliance. A surprising number of common items are now legally classed as hazardous, including television sets, computer monitors, batteries, many paints and oils and also fluorescent light tubes – all of which count towards the 200kg.

The principle of ‘producer responsibility’ is applied directly to manufacturing in the case of some of the newer pieces of legislation, where manufacturers now bear responsibility for the environmentally sound disposal of their products. This shift is evident in the Packaging Waste Regulations 2007, the WEEE (Waste Electronics and Electrical Equipment) Directive 2007 and in the forthcoming Batteries Directive. These are all driven by European Union Directives and are based on the principle that if you bring a product to market, you must also make adequate provision for its disposal.

Legislation that puts the onus on the original manufacturer to control the environmental damage caused by its products at the point of disposal is fundamentally altering the way we view waste. Both businesses and consumers are being encouraged to demand more from their suppliers; whether ‘more’ means reducing the amount of packaging they use, or reducing the hazardous nature of products or offering environmentally friendly disposal options for products at the end of their serviceable life.

A compelling financial incentive to change the way we view waste is the ever-increasing cost of disposal. As British organisations currently produce an estimated 434m tonnes of waste every year, there are significant economies to be gained from cutting the sheer quantity of material that we pay to consign to waste, and from looking into alternative processes such as recycling and recovery. This point was hammered home to many companies in April this year, when the Landfill Tax increased from £24 to £32 per tonne. This is set to continue rising every year so that, by 2010, it will be £48 per tonne.

As landfill is becoming an increasingly expensive and socially undesirable disposal option, FMs need to consider the range of alternatives available to them, and become less reliant on the traditional ‘black bag’ approach to waste management.

Segregating recyclable waste presents all businesses with the opportunity to reduce their waste disposal costs. In the case of high volumes of high value waste, however, there’s also the opportunity to make it pay. This is because some materials have a commodity value. By correctly segregating waste and then baling it, it becomes much more attractive to recycling companies, who will often collect it for free. And in the case of particularly valuable materials such as high-grade office paper, it may be possible to negotiate payment from the recycler.

Clean, clear plastic wrap, for example, can be sold on for up to £120 per tonne (price depending upon location, volume, presentation, contamination levels and accessibility of site). So bear in mind that a tonne of uncontaminated waste plastic wrap per week, stored in mill-sized balers in an accessible location would command a price; while a weekly wheelie bin full of plastic bottles probably wouldn’t. Other waste materials common in manufacturing, which are easily baled and recycled include cardboard (packaging) and metals.

Some specialist waste contractors will provide recovery and recycling services for less obvious categories such as fluorescent light tubes, computer equipment and batteries. Flourescent light tubes, for example, can be dismantled and segregated into their constituent parts - glass, metal end-caps and phosphor powder – each of which may be recovered and re-used. Now that fluorescent light tubes are classified as hazardous waste, it is important to check that contractors hold appropriate licenses, and that the relevant paperwork is supplied for compliance with the Environmental Protection Act and the Hazardous Waste Regulations.

One of the most common forms of recycling widely offered by the chemical waste industry is the processing and recovery of materials from industrial and manufacturing waste. Many liquid wastes for example can be processed to recover the metals and active chemical ingredients contained within them. This extends the serviceable life of these materials, while reducing the hazardous nature of the waste. The waste industry is actively developing these processes, to help reduce our reliance on landfill and incineration as the only practical waste disposal options.

It is unlikely that we will ever be able to adopt a 0 per cent landfill policy as production of some ‘general waste’ is unavoidable. However, there are many tried and tested recycling, recovery and alternative disposal routes available, which every organisation should consider in order to cut waste, safeguard the environment and achieve significant savings in the process.

As it will invariably be FMs who are required to implement policy and procedural changes relating to waste management and recycling processes, it is in their own interests to keep fully up to date with forthcoming legislative changes affecting them.

One of the best ways to stay informed is to build good, strong communication channels with internal Environmental and Health and Safety departments. Where these are not available, an organisation’s waste disposal contractor(s) should be able to provide a font of information on waste law. And a good source on the web is, which gives detailed guidance on all current environmental legislation and even has an email alert, to provide advance information on forthcoming changes.

However FMs choose to inform themselves, they need to accept that in today’s increasingly environmentally aware and legislated marketplace, a strong understanding of waste law is no longer an option, but a commercial imperative.

● Dr. Nick Williams, Safety, Health and Environment Manager with the PHS Group plc

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