7 May 2013
Waste management may not be a sexy issue, but from a cost perspective, it’s an increasingly important one.
By next year, the government’s Landfill Tax escalator will have seen the cost per tonne of sending waste to landfill increase by around nearly a half in just three years. Gradually, the cost of waste disposal is becoming
Understandably, the practice of segregating waste materials on site is becoming more attractive.Businesses in sectors such as manufacturing, hospitality, aviation and retail have led the way by looking at the type of waste they handle, segregating it into recyclable streams and reducing the amount that ultimately goes to landfill – together with the associated costs.
But while organisations in sectors dealing with large volumes of raw materials have been ahead of the curve, others have been more resistant to change or face barriers that make it difficult to do so.
For example, property management companies dealing with multi-tenanted typically pass the waste management cost on to tenants so may not directly feel the impact of rising waste costs. At the same time, office buildings present issues such as lack of availability of space for separating waste and storing multiple waste containers on-site.
In these circumstances, coming up with a waste management strategy involves getting buy-in from tenants, many of whom will change as their leases expire. Co-ordinating all of that can be an uphill battle, but, nevertheless it’s something that can be achieved as long as the necessary will exists. It’s a question of evaluating just how important for your organisation to have a sustainable waste management strategy, to be seen to be being green and to be compliant.
As well as those with a large throughput of raw materials, the companies likely to have committed to recycling tend to have a higher public profile or a commitment to a public position on corporate social responsibility. In other words, those scrutinised by the public are more likely to have a recycling policy that itself stands up to close scrutiny. Waste contractors
The best waste management operators are in fact recycling businesses that just happen to process a bit of residual waste (rather than the other way round) – a case of resource management as much as waste management. The profile of the sector has changed significantly as different legislation covering different types of waste (general, packaging, hazardous, electrical and electronic equipment, food, and so on.) and methods of disposal have led to greater complexity. For businesses, now designated waste producers, managing the necessary compliance issues has become much more of a burden.
And compliance is a key issue; as a waste producer, you are legally responsible for where the waste you generate ends up. You need to have clear audit trails that show where waste goes once it leaves you. Waste producers are encouraged by law to periodically follow their waste trail.
Questions you need to ask include: Can I go and see where the waste contractor takes my waste? Is the paperwork in place? As well as seeing the next link in the chain, can I get visibility of the whole chain? Can I have complete visibility of what goes where?
Working with waste management providers helps to maintain that paper trail, and there are a lot of capable waste management specialists you can call on. But it’s equally important to realise that the waste industry is changing at a rapid rate, developing new and more efficient ways of handling different waste streams.
In this regard it is comparable to the IT sector, where routine access to specialist advice and expert intervention is an important factor when weighing up how the overall business requirement is managed. Waste producers – or brokers?
Your reporting responsibility as waste producer is clear. In some cases, however, your business may also be defined as a waste broker. The Waste (England & Wales) Regulations 2011 force a requirement for all producers of controlled waste to:
- Confirm that they have applied the principles of the ‘waste hierarchy’ when transferring waste
- Declare compliance on transfer and hazardous waste consignment notes.
But some businesses may also be defined as waste brokers. The Environment Agency defines waste brokers as ‘people who make arrangements, on behalf of others, to recover or dispose of waste, regardless of whether or not they handle the waste themselves’.
That’s a description that covers the activities of my company, WCRS, but there has been uncertainty over whether this includes the activities of other companies. The Environment Agency has since made clear that where a letting agency makes arrangements for the removal of waste from rented accommodation, it is acting as a waste broker and should register in the upper tier. If a letting agent, shopping centre manager or site manager for another location, where businesses share waste facilities, arranges for waste produced by the various businesses to be removed, they should also register as a waste broker and dealer.
The EA has made it clear that this covers the activities of facilities management, property management and cleaning companies. In conclusion
Waste management is an increasingly complex requirement with compliance and CSR issues and a recent, steep rise in cost. Your policy for managing waste is ultimately a product of your organisation’s priorities, but your responsibility for managing waste is clear – and it’s a responsibility that requires close attention.
Tony Windsor is managing director of Waste Cost Reduction Services (WCRS). WCRS is the sponsor of the forthcoming BIFM Good Practice Guide to Waste Management. The guide will be distributed with a forthcoming edition of FM World