Sending surplus food to charity is not the way to reduce greenhouse gas emissions

,

Written by Elaine Power, Queen’s University, Ontario

This article is republished from The Conversation under a Creative Commons license. Read the original article.

With the recent news that Canada is warming twice as fast as the rest of the world, Environment and Climate Change Canada (ECCC) is calling for urgent action to reduce greenhouse gas emissions.

Reducing food loss and waste is one important action we can take. When food waste is sent to landfill, it decomposes to methane, which is 25 times more powerful than carbon dioxide as a greenhouse gas. In addition, food waste represents a tremendous loss of the energy, land, water and labour used to produce the food.

And we waste a lot of food. An incredible 58 per cent of all food produced in Canada is either lost or wasted. This is an enormous amount of food, worth almost $50 billion, according to a report by the Toronto-based food charity, Second Harvest.

The first proposed strategy, laid out by ECCC in a draft document circulated in early spring 2019 to academics and others with interests and expertise in addressing food loss and waste, is the most obvious: to reduce the amount of food that is wasted, most of which originates in food processing, production and manufacturing.

The second proposed strategy is to enhance the donation of surplus food to feed hungry people. This strategy appears to be a simple “no-brainer,” as demonstrated by the more than 233,000 Canadians who signed a Change.org petition to end food waste. The comments on the petition website show that many Canadians believe it to be morally wrong to waste edible food, especially when some Canadians are hungry.

However, while giving food that would otherwise go to landfill to hungry people may be a convenient part of a solution to reduce greenhouse gases, it will do little to ensure the well-being of the four million Canadians who are food insecure.

Reducing food waste by feeding hungry Canadians is a simplistic solution that is deeply problematic and morally distressing. It provides the comforting illusion of a solution to hunger while the underlying problem — poverty — is not addressed.

Food insecurity

Food insecurity — the inadequate or uncertain access to food because of financial constraints — is a symptom and result of poverty. It is a public health crisis, with profound consequences for individual health and for health-care costs. It cannot be solved by food charity.

Only one in five hungry Canadians use food banks. And even when they do, they remain food insecure. When food banks and soup kitchens distribute edible food that would otherwise go to landfill, it means that some hungry Canadians are less hungry than they would otherwise be. But food charity is not a solution to the problem of food insecurity.

Nobel Prize winner Archbishop Desmond Tutu has recounted the profound poverty affecting black South Africans when he was a boy. He explained that the free school meals provided to white — but not Black — school children were often thrown in the garbage in favour of homemade packed lunches.

Watching another Black boy rummaging in the garbage to find the food that white children had rejected was indelibly marked in his memory of childhood. “It was perfectly edible food. But I knew it was wrong,” he said. For Archbishop Tutu, the idea that some people have to eat the cast-off food that others do not want is a powerful symbol of profound, systemic injustice.

I expect he would be shocked that the government of one of the richest countries in the world, with an international reputation as a just society, would consider endorsing such a proposal.

The right to an adequate standard of living

While Canada has committed to the Sustainable Development Goal of halving per capita food waste globally by 2030 and cutting greenhouse gas emissions by 232 million tonnes by 2030, we must remember that we have other international obligations too.

In 2012, the UN Special Rapporteur on the Right to Food, Olivier De Schutter, expressed concern about the growing gap between Canada’s international human rights commitments and their domestic implementation. He recommended that Canada ensure income security for all citizens at a level sufficient to “enjoy the human right to an adequate standard of living,” which includes the right to food.

There is no reason why we cannot achieve our goals of reducing food waste and greenhouse gas emissions while also assuring all Canadians the income they need for an adequate standard of living, including the ability to buy their own food. Reducing poverty through effective public policy, such as the poverty reduction strategy introduced by the Government of Newfoundland and Labrador and the ill-fated Ontario Basic Income Pilot project, reduces food insecurity.

In a country as wealthy as ours, it is immoral, unjust and unconscionable that the Government of Canada would endorse a plan that effectively relegates four million Canadians to second-class citizenry by recommending that they eat the garbage that no one else wants.


Elaine Power, Associate Professor in Health Studies, Queen’s University, Ontario

The Conversation

Separating fact from fiction – are we really only recycling 9% of plastics?

,

Written by Calvin Lakhan, Ph.D, Faculty of Environmental Studies at York University

It seems like everywhere I turn, I see the headline “Canada only recycles 9% of its plastics” – this figure, taken from a report prepared by Deloitte for Environment and Climate Change Canada, has now become the focal point of both those within the industry and the general public alike.

For a country that prides itself on being environmentally conscious and engaged, can we really be doing that badly?

I want to start this post off by saying that I will readily admit to not knowing what % of plastics are recycled in Canada (or anywhere else for that matter). However, I would venture to say that nobody knows, and we should be cautious about taking any estimate at face value without fully understanding the methodology and limitations used to arrive at that figure.

How do we calculate a recycling rate?

For those of you well versed in the subject, feel free to skip ahead. However, it is important to understand how exactly recycling rates are calculated. At a high level, a recycling rate is total tonnes of waste recycled divided by total tonnes of waste generated. This seems simple enough, but this grade school arithmetic actually involves a tremendous amount of modeling, assumptions, and to be perfectly blunt, guess work.

Solid waste diversion and disposal, Canada, 2002 to 2016
(Source: Government of Canada)

Total Tonnes Recycled (The Numerator)

First, let’s consider the numerator in the equation – total tonnes of plastics recycled. For certain jurisdictions, (i.e. Ontario, British Columbia, Quebec etc.), total tonnes of residential plastics recycled is tracked by municipalities (using total tonnes of material marketed), who then subsequently report those figures to a provincial body. These figures are then summed and aggregated, to arrive at a figure for total tonnes of residential plastics recycled.

Generally speaking, tracking recycled tonnes for residential recycling programs is fairly straightforward, as these are actual measurements being reported by collectors. This sounds simple – until we are asked to determine total tonnes recycled by the IC&I (industrial, commercial and institutional) sector. The vast majority of all waste generated in Canada comes from the IC&I sector – by comparison, it is estimated that the residential waste stream makes up less than 20% of the overall waste stream.

As noted in a previous post, data surrounding plastics generation/recovery in the IC&I sector remains extremely poor, with little consensus regarding who is generating plastics waste, how much is being generated, and how much is being diverted.

The IC&I sectors consist of a range of establishments, including: malls, office buildings, construction and demolition sites, restaurants, hotels, hospitals, educational institutions, manufacturing plants, and multi-residential buildings.

Previous attempts to model IC&I recycling rates have ranged widely, with plastic diversion rates ranging from as little as 10% to as much as 80% depending on the sector and what actually constitutes diversion activity. The reason for this widely ranging disparity is that there is no formal legislative requirement for the majority of the IC&I sector to report the quantities or types of waste being generated, diverted or disposed to provincial authorities.

In Ontario for example, only large IC&I establishments are regulated under existing legislation (which requires establishments to have a formal waste diversion plan and conduct waste audits). However, it is estimated than 80% of waste generated from the IC&I sector comes from small and medium sized establishments, and thus, fall outside the purview of existing regulation. This issue is exacerbated in other provinces which have no formal legislation that monitors the IC&I sector, and relies on voluntary reporting to keep track of waste generation data.

In short, the majority of the plastic waste being generated across Canada is not being tracked – which makes the figures reported by Deloitte all the more curious.

As an intellectual exercise, think about your average food court for a moment and how much packaging waste is being generated (both recyclable and unrecyclable). Are shoppers putting all their papers in the recycling bin? Oops, somebody with a half full drink tossed it in and ruined the material. How many plastic forks, knives and straws are being handed out? Did the person taking out the trash really just put all the recyclables and garbage in the same bag? Variations of this chaotic scene plays out every day, all over the country, and somehow, I am supposed to believe that this is being tracked by the owners of establishments?

One of the reasons why legislation for the IC&I sector has been so challenging in Ontario (and nationally) is due to the poor quality of the data. Whatever estimates do exist, have largely been based on a relatively small sample of waste audits, and modeled using a combination of waste generated per employee estimates (by sector and by NAICS code). If this sounds confusing, it is – at no point have we ever been able to credibly quantify the total tonnes of material recycled for both the residential and IC&I sectors. At best, we are making educated guesses, and at worse, we are producing inaccurate estimates based on a flawed methodology.

In short, the majority of the plastic waste being recycled across Canada is not being tracked – however, this does not necessarily mean that this material is ending up in landfills.

On site recovery, reuse and recycling

Despite the fact that there is very little formal data for plastics waste that is being tracked, many IC&I generators (particularly in the industrial and manufacturing sector), rely on on-site waste management programs to reuse and recycle plastic waste. True to the spirit of a circular economy, many producers use plastic waste outputs from one part of their production process, as inputs for the next. Anecdotally, many producers claim diversion rates close to 100%, as any material of value is reused, recycled or reprocessed internally. It is estimated that more than 50% of all IC&I material being generated is managed using on-site options. While this makes sense intuitively, it is difficult to gather any firm data regarding the quantities or scale of on-site material management for plastics. As noted previously, existing legislation does not require this information to be reported, and as such, any data that is available is left to the discretion of private companies and associations to share publicly.

Previous attempts to gather this data (most recently by the Ontario MOECC in the IC&I Review conducted in 2014) was met with resistance from the IC&I sector, who claimed administrative burden and commercial sensitivity in collecting and sharing this data.

Total Tonnes Generated (the Denominator)

I could probably stop here having made the point that we are working with insufficient data – however, I am also writing this article so that people can fully appreciate what goes into calculating a recycling rate, as very few ever stop to ask how we come up with our numbers.

With that being, I now turn my attention to the denominator in the equation – total plastic waste generated. Unlike total tonnes recycled, which is something that can be measured and recorded using a weigh scale at a material recycling facility, total plastic waste generated is an entirely modeled number. For the residential recycling sector (Blue Box), producers of packaging are asked to report their unit sales into a given market, and generation rates for households are modeled using a series of assumptions based on population density, locality, urban/rural split etc. I have worked in this space for the better part of a decade, and I still could not tell you what exactly goes into the waste generation model used for printed paper and packaging.

Turning our attention back to the IC&I sector, there is no formal requirement for any establishment to report how much of a particular plastic waste they have generated into a market every year. Unlike printed paper and packaging, we cannot assume that unit sales is a proxy for waste generation, as many plastics are durable goods. To use a very simple example, a company may sell 1000 tonnes of plastic lumber into a market every year, but that doesn’t mean all 1000 tonnes will reach end of life during that period.

To accurately model the quantities of plastics needing to be managed at end of life, we would need to know its life expectancy, composition, primary and secondary use etc. To make a very long story short, you would almost need to do a mass balance of all plastics before we could credibly estimate overall generation. Simply put – we do not have that information, and even if it could accurately monitored and tracked, there is no legislative requirement for plastic producers to share that information.

Is “Ball Parking” good enough?

The exact findings from the Deloitte report said:

3.2 million metric tonnes ended up as garbage, 86 per cent went to landfill, 4 per cent to incinerators and 1 per cent — 29,000 metric tonnes — ended up as litter which can contaminate lakes and oceans. Most of the wasted plastic comes from offices, institutions or industries.

To be quite frank, I do not think the above numbers are accurate – however, does that really matter? I suppose that depends on what we are trying to achieve. If the purpose is to highlight that a significant percentage of our plastics is ending up in a landfill, necessitating immediate corrective action, then I am all for it. Communicating the size and scale of the problem is of greater importance than precision.

However, if our intent is to develop policy and legislation, particularly with respect to asking producers to pay for end of life costs associated with managing plastics at end of life, then we have to press pause.

Solid waste diversion rate by source, Canada, 2002 to 2016
(Source: Environment Canada)

Developing a data acquisition strategy

Identifying stakeholders who may have access and be willing to share sector specific data with respect to plastics generation/recycling/diversion will be critical in fully understanding the size and scope of the issue. It is only possible to achieve “Zero plastic waste” if we can understand how much is being generated, and what is presently happening to it.

Potential sources for this data include individual producers, industry associations and waste service providers. The latter has not traditionally been used as a source for data on tracking/measuring plastics waste, but waste service providers must often maintain detailed manifests regarding what they are collecting, and where they are processing it.

It is also the recommendation of this article that extensive research be conducted into on site waste management activity. As noted above, many manufacturing and industrial stakeholders claim to operate on site plastic recovery and diversion programs. However, access to this data (how much is being managed, how is it being managed (technologies, end use applications etc.) has historically been very difficult.

Designating who will be responsible for collecting and maintaining this information is also a critical early step in developing a successful circular economy. Many stakeholders have expressed concerns surrounding the sensitivity of sharing this data (for competitive/proprietary reasons), while provincial governments have cited lack of resources and administrative oversite to collect and maintain data repositories. This problem is compounded when attempting to gather data across multiple jurisdictions.

The report prepared by Deloitte was a critical first step in helping understand the plastic waste issue, but I would caution readers from jumping to conclusions when reading a sensationalized headline like: “Canada does a bad job at recycling plastics” – a more accurate statement would be “Canada doesn’t know what is happening to plastics at end of life”

About the Author

Calvin LAKHAN, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior. Calvin has worked as both a policy planner for the MOECC and as a consultant on projects for Stewardship Ontario, Multi Material Stewardship Manitoba, and Ontario Electronic Stewardship. Calvin currently sits on the editorial board for Advances in Recycling and Waste Management, and as a reviewer for Waste Management, Resources Conservation and Recycling and Journal of Environmental Management.

Who’s Making the Rules on Global Plastics?

, ,

Written by Jonathan D. Cocker, Baker McKenzie

There is no question that dramatic changes are coming for the supply and reverse supply chain for plastics that will impact packaging, containers, and plastic products. From resins and polymer mixes to ocean plastic clean up and waste export bans and everything in between, it is difficult to not foresee a fundamental regime shift coming for the regulation of plastics globally. But just who decides on these new rules and how will disparate initiatives and goals lead to convergence on legal standards?

EU Plastics Strategy

The first place to start is, of course, the European Union. The broad-reaching 2018 strategy encompasses the landmark 2019 Single Use Plastics Directive, targeting certain commonly disposed products and includes:

  • Bans for a number of single use plastics (cutlery, straws, etc.) where non-plastic alternatives are readily available and affordable;
  • Reduction targets for food containers and cups;
  • Ambitious collection targets of up to 90%;
  • Producer payment obligations to help fund waste management and legacy clean-up costs;
  • Labelling of some plastics, indicating how to waste dispose and alerts as to the negative environmental impacts of plastics; and
  • Consumer awareness campaigns about negative impacts of plastic litter and re-use and waste management options. 

In short, it is a policy mix impacting various parts of the life-cycle. The Plastics Strategy goes further, however, and requires of all plastics:

  • Design of recyclability;
  • Creation of markets for recycled and renewable plastics;
  • Expanding and modernizing EU’s plastics sorting and recycling capacity;
  • Mandating producer-paid initiatives to curb plastic wastes;
  • A regulatory framework for plastics with biodegradable properties; and
  • Coming regulation on microplastics across a number of industries.

This relatively comprehensive set of product and supply chain requirements would apply to both inbound and outbound products, leaving little room for global plastics industry stakeholders to remain untouched by these coming standards.

Ellen MacArthur’s “New Plastics Economy”

What the Ellen MacArthur Foundation lacks in regulatory authority, it more than makes up for in ambition. The seminal publications on a “New Plastics Economy” involves macro-level systems to remake supply/reverse supply chains. Overall, it’s mission is described as follows:

  • Elimination of problematic or unnecessary plastic packaging through redesign, innovation, and new delivery models is a priority;
  • Reuse models are applied where relevant, reducing the need for single-use packaging;
  • All plastic packaging is 100% reusable, recyclable, or compostable;
  • All plastic packaging is reused, recycled, or composted in practice;
  • The use of plastic is fully decoupled from the consumption of finite resources; and
  • All plastic packaging is free of hazardous chemicals, and the health, safety, and rights of all people involved are respected.

The genius of the New Plastics Economy Global Commitment is its multi-stakeholders industry approach, enlisting some of the largest industrials and other stakeholders from across the plastics supply and reverse supply chain to make concrete, shared undertakings, thereby establishing common terms of reference and objective standards by which supply chain parties can systematize their efforts.

They’ve gone further and fostered the growth of “Plastic Pacts” in which countries are to enlist domestic industry to make commitments which exceed EU standards. The reference terms are not, however, entirely consistent, potentially creating future challenges for international industry to adopt a single compliance legal regime where long-term investment under the MacArthur Foundation model isn’t entirely exported into law.

Alliance to End Plastic Waste

January 2019 also saw the creation of the industry-led Alliance to End Plastic Waste, which has committed an astounding $1.5 Billion over the next five years with a mandate to “bring to scale solutions that will minimize and manage plastic waste and promote solutions for used plastics by helping enable a circular economy”.

To date, the Alliance appears to be focused upon funding plastics-relevant waste management projects, principally in Asia, but their heft will, no doubt, be relevant in the overall direction of plastics policy given their petrochemical representation and their planned investments. It remains to be seen when and how they might enter the plastics product design-for-environment field.

Basel Convention

Finally, the newest major entrant in the increasingly crowded field of new plastics standards is the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal. In addition to the deeming of most plastic wastes as controlled by the environmental and transfer protections built into the Basel Convention effective January 1st, 2021, the May 2019 resolutions also put the organization into the forefront of plastics regulation with some notable initiatives:

  • An expert working group is to be convened to consider whether to expand the categories of plastic wastes which should be classified as “hazardous” under the Convention (many will be simply classified as “other wastes” under the May 2019 resolutions);
  • A “partnership on plastic wastes” is to be convened which will include the (state) parties to the Convention, as well as certain other stakeholders (as either parties or observers) and will:
    • Engage in pilot projects and scaling exercises;
    • Assess best practices, as well as barriers, for the prevention, minimization, and environmentally-sound management of plastic waste movements; and
    • Consider options for increasing durability, reusability, reparability and recyclability of plastics.
  • A mandate to update the current Technical Guidelines which are to be a point of reference of parties’ national and international waste management and recycling standards, including how they relate to plastics.

With these goals, the Basel Convention has gone from a virtual bystander on most plastic waste issues to an aspirant for a central role, with the backing of almost all national governments (notably absent – USA). Further, the Basel Convention has overtly called for collaboration with the United National Environment Program, giving it a further platform to push through multi-lateral action on plastics. Whether the Basel Convention lacks the industry integration to remain relevant in this dynamic market, however, remains to be seen.

Where’s the Convergence?

In looking at these four major global initiatives, what’s most staggering is that they’ve all arisen in the past year, each arguably filling a vacuum on plastics stewardship to which great public animosity was paid.

While each has a somewhat different mandate and maybe all would benefit from each pursuing their own enterprises for now, there will soon be a need for convergence on the fundamentals of future plastics rules, such as permissible plastics types, hazards eliminations, recycled content minimums, environmental attributes, such as “compostable” or “biodegradable”, design for recyclability, usage bans, and reverse supply chain integration.

Without convergent, plastics industry stakeholders won’t find the market stability necessary to make any of these initiatives successful.


About the Author

Jonathan D. Cocker heads the Firm’s Environmental Practice Group in Canada and is an active member of firm Global Consumer Goods & Retail and Energy, Mining and Infrastructure groups. Mr. Cocker provides advice and representation to multinational companies on a variety of environment, health and safety matters, including product content, dangerous goods transportation, GHS, regulated wastes, consumer product and food safety, extended producer responsibilities and contaminated lands matters. He appears before both EHS tribunals and civil courts across Canada. Mr. Cocker is a frequent speaker and writer on EHS matters, an active participant on EHS issues in a number of national and international industry associations and the recent author of the first edition of The Environment and Climate Change Law Review (Canada chapter) and the upcoming Encyclopedia of Environmental Law (Chemicals chapter).

Making Producers Pay – From Stewardship to Innovative EPR Programs in Canada

, , ,

Written by Mark Youden and Maya Stano, Associate Lawyers at Gowling WLG

Product and packaging waste is increasingly drawing public attention across the globe. This stems, in part, from a growing awareness of massive plastic pollution accumulation zones in our oceans, government bans of single use plastics, China’s recent import ban on scrap plastics, and news of the Philippines wanting to return Canadian “recyclables.”  In this era, governments are increasingly turning to innovative waste management and diversion policies and laws.

To date, Canada has focused on two approaches for managing products and their packaging at end-of-life: (1) extended producer responsibility or “EPR”, and (2) product stewardship programs. For the most part, these programs (which cover various categories) fall under provincial jurisdiction.    

To varying degrees, these programs shift the end-of-life waste responsibility away from governments (and tax payers) and on to producers (e.g., brand owners, manufacturers and first importers).  Depending on the program, this responsibility includes reporting and funding (at least in part) the management of the waste created by their products.  

Stewardship versus EPR

Although often used interchangeably, there are key policy differences between product stewardship and EPR programs (as well as significant corresponding financial implications for companies). Generally speaking, EPR programs place responsibility (and costs) on product producers, whereas product stewardship programs generally rely on consumer-paid environmental fees or public funds. Although the emphasis in Canada has historically been on product stewardship programs, there is a growing shift towards transforming those initiatives to full-fledged EPR programs. Such EPR programs place full responsibility for designing, operating and financing diversion programs, and accountability for the program’s environmental performance, on producers.  The concept is intended to incentivize companies to not only bear responsibility for, but actually reduce, their product waste footprint (e.g., through recyclable product and packaging innovation).

Status of EPR Programs

Provincial Level

In 2014, British Columbia became the first jurisdiction in Canada to implement an EPR system making producers fully responsible for funding and managing curbside and drop-off recycling programs for packaging and printed paper. Under the province’s Environmental Management Act and Recycling Regulation, producers must recover 75% of the paper and packaging they produce, and face fines if they don’t achieve this target.

Full EPR programs have not yet been implemented in other provinces – some provinces do require producers to pay for part of their recycling, but none outside of BC require producers to manage the actual system. At the local level, municipalities often bear the burden of dealing with urban waste generation, and towns and cities are increasingly expressing support for full EPR implementation to help cover the costs of expensive recycling programs. For example, the City of Calgary recently passed a motion to push the province into looking into EPR programs. 

Similarly, in Ontario producers are required to pay for 50% of the recycling system, but municipalities are actively calling for a full EPR model. In 2016, Ontario passed a groundbreaking bill that instituted an EPR requirement for all product categories. The bill also sought to prevent producers from discharging their liabilities to a third party, thereby making them fully responsible. These efforts culminated in the adoption of several new laws, including the Waste Diversion Transition Act, 2016 (which includes payments to municipalities to cover their costs associated with the blue box recycling program), and the Resource Recovery and Circular Economy Act, 2016 (which led to the development of the Strategy for a Waste-Free Ontario: Building the Circular Economy).

Federal Level

At the federal level, the Canadian Council of Ministers of the Environment began taking action in the late 1990’s in regard to its waste reduction target of 50% of the product waste that is placed into the market. Since 2004, the CCME has published several reports, analyses, studies, tools and progress reports in regard to the Canada-wide Action Plan for Extended Producer Responsibility, with product packaging recognized as a priority in that plan.

International Level

EPR has a long history in Europe, where it has existed in varying forms since 1990. Sweden and Germany led the way by encouraging industries that made and sold products to be responsible for the waste stage of those products. EPR programs subsequently spread to other EU countries and beyond.

Challenges with recycling recently led to the EU’s approval of a law banning 10 types of single-use plastics by 2021 as part of its shift towards a circular economy (which aims to keep resources in use for as long as possible, extract the maximum value from them whilst in use, and recover and regenerate products and materials at the end of each service life). Canadian federal MP Nathan Cullen has recently introduced a private member’s bill, Bill C-429, the Zero Waste Packaging Act, which seeks to follow the EU lead.1 Stay tuned on the progress of those efforts as they evolve here in Canada.

The Spotlight on Product and Packaging Waste

A dispute between the Philippines and Canada has recently drawn attention on Canada’s product and packaging waste system.  In April 2019, the Philippines demanded that Canada take back shipping containers full of waste and recyclable plastics. Canada originally argued that it is not responsible for returning the waste that was shipped. This dispute, spanning over 5 years now, is complicated by obligations under international law (including the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, 1992).  As threats from the Philippines President escalated in late April 2019, Canada offered to accept and pay for the return of close to 70 shipping containers.Those containers are now on their way back to Canada. 

This international dispute has placed the spotlight on the state of recycling in Canada (as many did not realize Canada ships its waste elsewhere).  This, coupled with the public criticism over the effectiveness of Canada’s recycling regime, could spark local governments to expedite implementation of waste reduction policy and full-EPR programs. 

In summary, EPR and product stewardship programs are here to stay and will increasingly impose significant requirements on product producers.  Our Gowling WLG team has extensive experience in the detailed requirements that must be followed to ensure legal compliance. Should you have any concerns or questions regarding your company’s product stewardship and EPR duties, please contact one of our knowledgeable team members.


1 https://www.parl.ca/DocumentViewer/en/42-1/bill/C-429/first-reading#enH123


NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as, legal advice. You should not rely on, or take or fail to take any action based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. Gowling WLG professionals will be pleased to discuss resolutions to specific legal concerns you may have.

About the Authors

Mark Youden is an associate lawyer in Gowling WLG’s Vancouver office, practising in the firm’s Environmental and Indigenous Law groups. Mark is called to the bar in British Columbia, Alberta and Ontario and advises a wide range of clients on all aspects of environmental, Indigenous and regulatory law issues.

Prior to studying law, Mark obtained a Master of Science focused on biophysical interactions and the fate of contaminants in terrestrial and aquatic systems. He also worked as an environmental consultant for an international engineering firm.

Mark’s scientific expertise and multidisciplinary approach to the law help him provide clients with practical solutions to complex environmental and Indigenous law matters.

Maya Stano is a Vancouver-based Gowling WLG associate lawyer who practises natural resource, environmental and Indigenous law.

Maya has a wide range of legal experience assisting individuals, companies and Indigenous Nations and other levels of governments on natural resource projects, including mining, forestry, large and small scale hydro projects, oil and gas projects, and nuclear projects. Maya provides timely and effective advice at all stages of project life, from early planning and tenure applications, through construction, operations and final closure, decommissioning and reclamation. Maya’s services cover due diligence matters, permitting (including environmental assessments), land rights (including leases and other land access and tenure agreements), regulatory compliance, and engagement and agreement negotiations between First Nations, the Crown and proponents.

Maya also assists Indigenous Nations in various government-related matters, including drafting laws and bylaws, drafting and implementing trust instruments for sustainable long-term financial management, managing land use and rights on reserve, and working with land codes and other governance matters.

Maya studied law at the University of British Columbia, graduating with a specialization in environmental and natural resource Law. After graduation, Maya clerked at the Federal Court of Canada for the Honourable Mr. Justice John A. O’Keefe. Concurrently, she completed an LLM at the University of Ottawa, focusing on the legal implications associated with lifecycle management of metals.

Maya is also a professional geological engineer and previously worked on mining projects both domestically and abroad, as well as on contaminated sites across British Columbia, and on oil and gas projects in northern Alberta.

Waste Not, Want Not: Recycled vs. Recyclable

, , ,

Written by Calvin Lakhan, Ph.D, Faculty of Environmental Studies at York University

This past weekend, at a gathering with friends, the topic of recycling came up.

“Did you know that they can recycle cigarette butts now?”

Being known as the “garbage man” among my peers, eyes turned to me to confirm this seemingly revolutionary advancement in recycling.

I hesitated, knowing that my answer was about to make me a “Debbie Downer” and open a can of worms about what it really means to recycle something.

“No – cigarette butts cannot be recycled in conventional recycling systems” – I made sure to add the latter as a qualifier.

“But I heard about a program that takes back used cigarettes and turns it into new forms of plastic and compost!”

What my friend was referring to was the breakthrough program offered by Terracycle (read more about it here: https://www.terracycle.com/en-US/brigades/cigarette-waste-recycling).

And with a heavy heart, I launched into a lecture about the difference between something that can be recycled, versus something that is recyclable.

By the end, the disappointment in the room was palpable – I was the proverbial wet blanket that ruined the “feel good factor” of trying to do the right thing.

My feelings towards Terracycle and other similar organizations are heavily conflicted. On one hand, they are innovative, transformative and committed to finding new uses for problematic materials. The accolades they receive are well deserved, but I also think it creates a dangerous perception among the public about what items can (and should be) recycled.

Most materials can technically be recycled – be it cigarette butts, laminated coffee cups, chip bags etc. Given the resources, infrastructure, technology and time, we can find ways to re-purpose problematic materials.

It is in this space that organizations such as Terracycle thrive – they have forged literally dozens of partnerships with companies across the globe to successfully “recycle the unrecyclable”.

Win, win situation, right? Wrong.

While it may seem novel to turn ocean plastic into shoes, or chip bags into handbags, the hard truth is that this type of recycling cannot be readily replicated at scale. The processing technology involved is economically prohibitive, and really only available in jurisdictions in which the collection program is being offered.

The latter point is also why the environmental and economic impact of a decentralized logistics network is questionable – take back programs that ask consumers to ship things like coffee pods, chip bags, razors etc. hundreds of kilometers can be both inefficient and costly.

Going back to our cigarette butt example, there is no recycling facility in Canada (that I am aware of) that can economically recover the material… which is why it is so imperative that we distinguish between something that can be recycled, versus recyclability.

To me, the former is a technical question – does the technology exist to recycle a particular good? The latter however is a much more nuanced question that requires us to consider the economic, environmental and social impact of recycling activity.

As an example, 99.99% of people who work in waste will tell you that glass can be recycled, but I would bet that a significant portion of those people would question whether it should really be recycled (at least in a curbside collection system).

Why this matters is that the average consumer has difficulty differentiating between recycling and recyclability. Much like my well intentioned friends, once people hear that something can be recycled, they assume that to be a universal truth. When Keureg teamed up with Recycle BC to pilot a recycling program, people across the country thought that they could now put K-cups in their Blue Bin (which was never the case).

Perhaps a more insidious example of how this consumer confusion can result in catastrophe, is in the green washing of packaging. My social media feed is full of examples of CPG companies partnering with Terracycle (and others) to pilot new recycling programs. The dangers of this is that companies may be more concerned with the “optics” of recyclability, as opposed to developing products that can be sustainability managed at end of life. The key to a successful pilot is accountability and transparency – I don’t want a headline announcing a partnership, I want to know how much is being diverted, where it is being diverted and at what cost.

I want to impress upon the reader that this post is not about bashing Terracycle or any other company attempting to develop new ways to recycle problematic materials. Their work is critical in promoting consumer awareness, and has successfully married CPG companies and recyclers to work collaboratively.

However, we have to remember that recycling is only one of many tools we have to promote a circular system. Inordinately focusing our attention and resources on recycling may be at the expense of other, more sustainable options. Consumers have an intense appetite and interest in doing the right thing and keeping material out of landfills, but we have to be honest with both them and ourselves regarding the role recycling can play.

About the Author

Calvin LAKHAN, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior. Calvin has worked as both a policy planner for the MOECC and as a consultant on projects for Stewardship Ontario, Multi Material Stewardship Manitoba, and Ontario Electronic Stewardship. Calvin currently sits on the editorial board for Advances in Recycling and Waste Management, and as a reviewer for Waste Management, Resources Conservation and Recycling and Journal of Environmental Management.

Cities and countries aim to slash plastic waste within a decade

, , , , ,

Written by Dr. Chelsea Rochman, Assistant Professor of Ecology and Evolutionary Biology, University of Toronto and Dr. Diane Orihel, Assistant Professor, School of Environmental Studies, Queen’s University

If all goes well, 2030 will be quite a special year.

Global and local community leaders from more than 170 countries have pledged to “significantly reduce” the amount of single-use plastic products by 2030. Success would result in significantly less plastic pollution entering our oceans, lakes and rivers.

Today, societies around the world have a love affair with disposable plastics. Just like some love stories, this one has an unhappy ending that results in plastic bags, straws and takeout containers strewn about the global environment.

As researchers who study the contamination and effects of plastic pollution on wildlife, it would be nice if by 2030 we no longer heard about plastics showing up in the stomachs of dead whales, littering the beaches of distant islands and contaminating tap water and seafood.

Plastic doesn’t belong on the beach. Shutterstock

It is time for some good news about the environment, including stories about how cities and countries are managing plastics and other waste materials in more sustainable ways, and how children will have cleaner beaches to play on.

No reason to wait

Scientists have known about plastic pollution in our oceans for more than four decades. It is pervasive in rivers, lakes and soils too. Plastic pollution knows no boundaries, with small bits of plastic found from the equator to the poles and even on the remote slopes of the French Pyrenees mountains.

Plastic waste damages ecosystems, smothers coral reefs and fills the bellies of sea life. In the absence of action, the amount of plastic waste produced globally is predicted to triple between 2015 and 2060, to between 155 and 265 million tonnes per year.

As a welcome response, global leaders have decided to act. At the UN Environment Assembly in Nairobi in March, environment ministers from around the world signed a voluntary commitment to make measurable reductions in single-use plastic products, including straws, shopping bags and other low-value plastic items that are sent to landfill after being used once.

Similar goals to deal with plastic pollution have been introduced by municipal, provincial, federal and regional governments across the globe. Non-profit organizations and industry leaders are making efforts to tackle the problem of plastic pollution. For example, Ocean Conservancy is uniting citizens and organizations around the world in cleanups to meet their goal of an ocean free of plastics by 2030, and Unilever has pledged to use 100 per cent recyclable packaging by 2025.

Canada joins the movement

Canada introduced the Ocean Plastics Charter at the G7 summit in 2018, committing nations to work with industry to make all plastics reusable, recyclable or recoverable by 2030. That means sending no plastic waste to landfill.

Vancouver aims to be a zero-waste city by 2040. Although the city has reduced the mass of waste going to landfill by 23 per cent since 2008, it still has a long way to go.

Ontario also has its sights on being waste-free by developing a circular economy, which means keeping materials in use for as long as possible. The province aims to cut the amount of waste sent to landfills in half by 2030, a reduction of 4.5 million tonnes, through reuse and recycling.

To propel Ontario into action, Ian Arthur, the member of the Ontario provincial parliament for Kingston and the Islands introduced a private member’s bill in March to eliminate Ontario’s use of non-recyclable single-use plastic products such as straws, coffee cups and plastic cutlery, which ultimately end up in landfills. These plastics do not feed into a circular economy.

In addition, school children in Ontario are working towards collecting 10,000 signatures on petitions to ban single-use plastics in the province.

Canadians would like to see more action against plastic waste. According to a recent poll, 90 per cent of Canadians were either very concerned or somewhat concerned about the environmental impact of plastic waste, and 82 per cent thought government should do more to reduce plastic waste.

Bye bye plastic waste

Our research, and the research of others, has found that single-use plastic products litter our beaches and coastlines, small pieces of plastics contaminate our Great Lakes and the Arctic Ocean, and microplastics are present in our sport fish and drinking water.

Ambitious global, regional and local collaborations are sorely needed to truly realize these goals. It’s time to commit to ending the love affair with disposable plastics.

Individual action does work. Quench your need for caffeine by using a reusable mug. Hydrate with water from a durable and refillable bottle. Purchase groceries that come in containers that can be reused or recycled. Plan your kid’s birthday party and your work meetings without using disposable single-use plastics.

A decade of positive habits could lead to a future where plastic is no longer waste, but valued as a material that can be reused and recycled — shifting our current paradigm to a more sustainable one that lasts far beyond 2030.



This article is republished from The Conversation under a Creative Commons license. Read the original article.

About the Authors

Dr. Chelsea Rochman is an Assistant Professor of Ecology and Evolutionary Biology, University of Toronto. Previously, she was a David H. Smith Postdoctoral Fellow at the Aquatic Health Program at the University of California, Davis. Dr. Rochman received her PhD in a joint program with San Diego State University and UC Davis in Ecology.

Dr. Diane Orihel is an Assistant Professor, School of Environmental Studies, Queen’s University, Ontario. Dr. Orihel investigates human impacts on aquatic ecosystems through large-scale, multidisciplinary and collaborative research programs. She holds a B.Sc. (Honours) in Ecology and Environmental Biology (University of British Columbia), Masters in Natural Resource Management (University of Manitoba), a PhD in Ecology (University of Alberta). She was a Banting and Liber Ero postdoctoral fellow at the University of Ottawa, and now holds the position of Queen’s National Scholar in Aquatic Ecotoxicology in the Department of Biology and School of Environmental Studies at Queen’s University.

Extended Producer Responsibility for Textiles? Not So Fast…..

, ,

Written by Calvin Lakhan, Ph.D, Faculty of Environmental Studies at York University

In the Ontario Environment Ministry’s Reducing Litter and Waste in Our Communities Discussion Paper, the question was posed:

What additional materials do you think should be managed through producer responsibility to maximize diversion?

Stakeholders from across the used textile collection sector highlighted textiles as being a potential candidate for extended producer responsibility (EPR).

Given the hundreds of thousands of tonnes of used textiles being generated annually, it seems only logical that producers should be tasked with the physical and financial responsibility for managing these items at their end of life.   

However, when the university was asked to take a position supporting a producer responsibility scheme for textiles, I hesitated.

I want to preface this by saying that I feel that producer responsibility has a place in promoting a circular economy – In theory,  EPR is supposed to encourage design for the environment (have producers use more sustainable materials), promote positive environmental outcomes (increased diversion), and contain costs (incentive to minimize costs associated with end of life management).

Would EPR for textiles achieve these desired outcomes?

Before answering this, let’s remember what EPR is actually designed to do –  EPR is a cost recovery tool to finance the operational and administrative expenses associated with managing a material at its end of life.

Steward fees (what industry pays to finance a producer responsibility program) is based on net cost of material management. As an example, the fees associated with Blue Box materials are in direct proportion to the system costs attributable to said material. For packaging like plastics film and polystyrene, producers pay an extremely high steward “fee” because the net cost of material management is in excess of $1500 a tonne. Conversely, aluminum producers do not pay any fees, as they have a negative net cost (the revenue received supersedes the cost of material management).

Why this matters for textiles is that at present, net cost of material management for textiles is negative. Due to the high value of used textiles as a commodity, numerous organizations from across the for profit/not for profit sector collect used textiles, using a range of collection mediums.

Textiles, unlike most other waste streams, are being collected by third party operators, even in the absence of material specific legislation. The value of used textiles results in a self-sustaining collection network that ultimately negates the need for cost recovery schemes such as extended producer responsibility.

There is even an argument to be made that the low diversion rates for textiles is attributable to a lack of opportunity and awareness among households (as opposed to a lack of organizations willing to collect the material).

At present, there are no *net* costs to recover for used textile collectors, and EPR becomes moot.

Where this situation may change is in situations where used textile collectors begins to incur operational expenses that exceed the revenue that they receive from the material. This could be attributable to any number of things – management of low grade materials that have minimal value at end of life, a decrease in commodity value (due to either increasing supply of used textiles, or decreases in demand), and the development of domestic processing/recycling capacity that require infrastructural investments.  In these instances, EPR could be seen as a potential cost recovery tool.

Practical challenges to implementing a producer responsibility scheme for textiles

If EPR is adopted at a provincial (or national) scale, we must be cognizant of the enormous administrative challenges of developing such a program. The creation of an IFO/ISP, calculating and collecting fees, disbursing fees to service providers etc. are all necessary steps when developing a producer responsibility program.

Furthermore, the technical challenges of being able to readily quantify end of life material management costs, and then allocating those costs to specific stewards will require a fundamental overhaul in how we collect and interpret data related to textile generation/recovery. Of note, all EPR programs differentiate fees based on product or material type (i.e. a fee for a television is greater than the fee for a cell phone because of the differences in end of life management costs). This process would need to be replicated for all textile types being sold into the market in order to correctly allocate costs.

Simply put, formal programs for textile diversion are in their infancy, and we are still a long way from having the understanding to conceptualize what a producer responsibility scheme might look like. To provide context, Ontario’s Blue Box, which has had a (partial) producer responsibility scheme for the better part of two decades, continues to struggle with how to reconcile the opposing interests of both stewards and municipalities. It is a highly contentious process that is fraught with difficulty as stakeholders try to determine what is fair and reasonable.

Be careful what you wish for

While most stakeholders involved in used textile collection advocate for EPR, it is important to keep in mind that under a 100% EPR model, stewards will assume ownership of all recovered materials. While yes, they will be physically and financially responsible for all end of life material, they will also be entitled to the revenue received from the sale of that material.  

At present, it is unclear what the implications of a 100% producer responsibility model would be for used textile collectors, particularly in the charitable/not for profit space. Stewards may ultimately decide to rely on the existing collection networks in place (as opposed to doing it themselves), and designate certain organizations as a preferred service provider. It is entirely possible that charities/not for profits would then compete with other collectors to be a service provider, essentially reverting to a “bid/tender” process.

What should we do?

While the future of textile legislation, and what role EPR should play remains unclear, the key to developing a sustainable, circular textile market lies in flexible, non-prescriptive legislation. A necessary first step is to designate textiles as a priority material, but leave it up to the market to organically develop solutions to keep material out of landfill, and maximize the economic, environmental and social impact of recovery. Rapid changes in textile end markets, the types and quantities of textiles being generated, and technologies to recycle/reprocess textiles requires legislation that can grow and adapt to reflect the conditions of an evolving market place.

Note: This article reflects the sole opinion of the author. He does not speak on behalf of the university or any of its stakeholders.


About the Author

Calvin LAKHAN, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior. Calvin has worked as both a policy planner for the MOECC and as a consultant on projects for Stewardship Ontario, Multi Material Stewardship Manitoba, and Ontario Electronic Stewardship. Calvin currently sits on the editorial board for Advances in Recycling and Waste Management, and as a reviewer for Waste Management, Resources Conservation and Recycling and Journal of Environmental Management

Motor Oil Recycling: Barriers and Breakthroughs

, , , ,

Written by Zachary Gray, B.Eng.Biosci., Chemical Engineering & Bioengineering

Motor oil changes are a sacrament in our car-obsessed modern life, while the mechanics working in the auto shops are their enforcers and evangelizers.  Every 5,000 to 8,000 kilometres, car owners begrudgingly schedule an oil change between busy work days and weekend errands.  

Primer of Motor Oil

During the 20-minute oil-change procedure, mechanics bleed the blackened, viscous motor oil from the bowels of the engine and replace it with pristine liquids from bright plastic packaging – eye-catching to some, but a far cry from the painted metal containers that furnish collector’s shelves.

Vintage Motor Oil Can, $31 (USD) on ebay

While the myriad of car oil brands available might suggest a wide variance in products, they differ only in the precise mixing of additives.  Motor lubricant is essentially 70-80% base oil with the remaining 20-30% consisting of supplements such as antioxidants, detergents, and viscosity enhancers, as well as rust inhibitors.

The quality of the motor oil degrades over time in a motor vehicle.  The build-up of debris blackens the oil, while the additive properties deteriorate over the driving cycle, dissipating heat and lubricating contact points between metal parts with less efficiency as time marches onward.  Water entrainment and oxidation of the base oil are also contributing factors.  

Changing one’s motor oil frequently, as the chorus drones on, ensures the longevity of the engine. One question remains as the mechanics dispense with the last of the used oil: what happens to it afterward?   Nothing much is often the answer. 

Motor Oil Re-refining

There are over 300 million registered vehicles in Canada and the United States alone, contributing to the nearly 2.5 billion gallons of motor oil disposed of annually throughout North America.  Of the almost 60% recovered, a mere 8% is recycled. The remainder feeds the 12 billion of gallons of lubricant reduced to toxic waste yearly.

Catastrophizing about the volumes quoted and their impact is not productive in and of itself.  Exploring ways to improve oil recycling figures is a better use of time.

In 2009, when the revered Scientific American explored whether motor oil could be recycled, the editors profiled Universal Lubricants (“UL”).  The Wichita-based company uses conventional refining techniques from upgrading crude oil when recovering the spent lubricant.  They essentially re-refine the used motor oil

UL processes over 45.4 million litres of used motor oil, or 28,600 barrels, per day.  In the re-refining process, used oil passes through a vacuum distillation unit which removes water from the base oil, accounting for 5-7% of the incoming volume. Next, contaminants are removed using an evaporation press.  In the final step, UL hydrotreats the decontaminated oil. 

Hydrotreating consists of applying high temperature and pressure (700 deg-F and 1,100 PSI) and enriching the carbon-backbone of the oil with hydrogen molecules in the presence of catalysts that aid in the chemical reactions. 

The final product resembles base oil, ready for lubricant merchants to add their additive concoctions and branding power.

Photo Credit: UL

Re-refining efforts, much like those by UL, accounts for only 10 percent of used oil management market.  The majority of used motor oil is either burned or dumped, depending on the jurisdiction and level of enforcement.  The emergence of re-refining technologies has done little in altering the outcome for spent motor oil — but why?

Barriers to Recycling

There are two main barriers to a broader adaptation of re-refining used motor oil.  The first is the capital expense in building and operating a facility on UL’s scale.  Investors should expect a final bill of tens of millions of dollars in replicating UL’s plant in Canada.  Recovering their investment is another issue: refineries derive their profits either from large volumes, amplifying small gains per unit of measurement, or upgrading cheaper base stocks.  With respect to the latter point, one could argue that the used motor oil would be a commodity instead of merely a waste product with broader market adaptation.  Such a classification diminishes the facility’s economic viability.

The second barrier to re-refining is the plant’s environmental impact.  A re-refiner has a similar environmental impact as an oil refinery.  To understand how difficult it is to get environmental approval for an oil refinery, one need to realize that the newest oil refinery in Canada is over 30 years old.

Canadian Innovation

Besides re-refining, there are innovative and arguably more feasible solutions for recycling motor oil in development.  The Ottawa-based MemPore Environmental Technologies Inc. (“MemPore”) is one such example, scaling their locally-minded, membrane-based process.

MemPore’s solution is this: the used motor oil is kept in 5,000-gallon settling tanks and periodically shipped to their regionally-based operation.  The central locations reduce the amount of pollution from transporting oil over longer distances and eases logistical challenges.  After removing contaminants during the pretreatment process, consisting of a filter, centrifuge, and flash evaporators, the oil is sent to the membrane unit.  Once polished to a quality consistent with a regular base oil, lubricant mixers take the final product and infuse it with their additives.

Cement kilns take the waste sludge separated by the membrane. The 15 metric tonnes, or 148 barrels, per day system operates at low temperatures and pressures, thus reducing its running costs and environmental impact.

Mempore Used Oil Recycling System

Alastair Samson, MemPore’s CEO, eloquently summarizes the company’s position and value proposition:

“The MemPore System can, for the first time, recover and recycle this base oil with 71% reduction in pollution, from localized systems, using low energy, and at low capital and operating cost. This is an important contribution to the clean technology movement and the preservation of earth’s natural resources.”

MemPore’s community-centric and scalable solution, with the potential for handsome profit margins, offers a tangible solution to the endemic squandering of used motor oil.  They also provide the mechanics a new hymn during drivers’ reluctant excursion to the auto body shop.

Where will our next diverted tonne come from? Diversion with a purpose

,

Written by Calvin Lakhan, Ph.D, Faculty of Environmental Studies at York University

Provincial diversion rates have largely stalled in the past five years, and in fact, is trending downwards for the first time in more than two decades. The reason for this stagnation is heavily debated – some point to the proliferation of light weight packaging, while others suggest municipal inefficiency and lack of applicable legislation. Whatever the cause, the reality is that it is becoming increasingly difficult to divert “the marginal tonne”- where will our next diverted tonne come from? What will it cost? And what will be the environmental, economic and social benefit?

What makes this issue particularly salient is that municipalities across Canada continue to set lofty diversion targets as a first step towards achieving a circular, zero waste economy.

The next tonne will not come from printed paper and packaging (Blue Box)

While Ontario’s Blue Box program has been an enormous success and should be heralded as a pioneering initiative with respect to recycling and stewardship, it is unlikely that future increases in recycling and diversion rates will come from Blue Box materials.

Much of this can be attributed to the “evolving tonne” of what we find in the Blue Box – increasingly, packaging producers are moving towards light weight, composite plastics, while generation of printed paper has fallen precipitously since the early 2000s. Infrastructure for the recovery of printed paper and packaging was largely designed around “core materials” -newsprint, OCC/OBB, Metals, Glass and PET/HDPE. As a result, municipalities have struggled to adapt to rapid changes in the packaging mix, resulting in rising operational costs and stagnant recycling rates. As shown in Figure 1, net costs for the program have more than doubled in the past 15 years, while recycling rates peaked in 2012, and have trended flat (or downwards) since. 

No alt text provided for this image

To make a long story short – Ontario has essentially maxed out on what we are able to economically recover. Recycling rates for “core materials” are in excess of 90%, and households are already doing a great job of diverting materials that they readily recognize as being recyclable. While it is possible that future increases in diversion may come from composite/light-weight materials, doing so would have an enormous financial impact on the system. At a certain point, we have to ask ourselves, is recycling these materials worth it?

Organics is the next target waste stream

Given that future increases in diversion are unlikely to come from the Blue Box, the next logical choice would be to target the organics stream. While Green Bin programs have been adopted in several municipalities in both Ontario and across Canada, there is a significant opportunity to increase diversion (and achieve waste reduction) through initiatives that keep organics out of landfills (food waste avoidance, source reduction etc.)

Ontario has already signaled their intention to make organics a top priority moving forward, considering options such as an organics landfill ban, and encouraging the development of organics processing infrastructure. However, developing the requisite collection and processing infrastructure to divert organics is a resource and time intensive pursuit. While the organics stream is likely (and should be) where future diversion is likely to come from in Ontario, it is time for the province to think beyond the Blue and Green Box, and examine how to achieve incremental diversion through non-conventional waste streams

Textiles and Furniture – A Missed Opportunity

Textiles

At present, there are no legislative mandate for municipalities to manage textile waste. As a result, most municipalities across both Ontario and Canada do not include textiles as part of their diversion programs, largely due to a lack of both collection and processing infrastructure.

Textile waste is estimated to make up between 5-10% of the overall waste stream, with more than 1 billion pounds of textile waste going to Ontario landfill sites every year. As a result, it seems prudent that municipalities identify ways to divert this material from landfills, as it represents a significant missed opportunity.

Textiles, unlike most other waste streams, are a high value commodity, with numerous organizations from across the for profit/not for profit sector collecting used textiles. Despite the absence of a legislative mandate, service providers compete to collect textiles due to the potential financial incentive. Given that non municipal actors are willing to manage end of life textiles, what role can municipalities play in facilitating this collection in a way that maximizes both environmental and economic outcomes?

Municipal Branding

Unlike other waste streams, convenience is not the most significant predictor of household participation. This finding is atypical to any other waste stream (such as WEEE, or PP&P), as households have a “value attachment” associated with their used clothing. As such, households indicate a very strong preference for ensuring that their donations go to a cause they personally identify with (charitable, social, environmental etc.).

The primary impediment to household participation results from uncertainty surrounding the “outcome” of their donation. This uncertainty is attributed to the presence of charity masqueraders (for profit textile collectors), who deceptively brand themselves in a way to suggest that they are a charity. Many of these organizations lack transparency with respect to the destination of the material, or what is being done with the proceeds from the donation. This confusion is sufficient to deter households from participating in diversion activity. Stated alternatively, households would rather throw their textiles in the garbage, than donate their items to duplicitous textile collectors.

To specifically address this uncertainty, municipalities should designate preferred textile collectors within the community (using municipal branding on bins, or some other form of official recognition). This branding/recognition clearly communicates to residents that “approved collectors” are adhering to best practices in funding transparency, accessibility and service standards. The intent of this municipal vetting process is to reduce consumer uncertainty regarding both the collector of the material, and the destination of the donation.

Environmental Benefits

Given the sheer quantity of textiles that are ending up in landfills, increasing diversion rates will have a significant environmental benefits. The environmental impact from diverting 10,000T of textiles are shown in figure 2 below: 

No alt text provided for this image

Keep in mind that there is an estimated 250,000T of used textiles available for collection each year in Ontario – diverting even a fraction of this material will help both municipalites and the province achieve carbon reduction and diversion goals.

Economic Benefits

The economic impacts of designating preferred collectors transfers all end of life management costs onto the service provider. Municipalities and retailers do not bare any direct costs – in fact, for every tonne diverted, municipalities save money through avoided landfilling and processing costs. The value of textiles as a commodity results in a self-sustaining collection infrastructure that negates the need for cost recovery schemes such as extended producer responsibility (EPR). This helps minimize the administrative burden of developing an EPR program, and allows for an approach that can be readily replicated in jurisdictions across Canada.

Social Benefits

While numerous textile collectors are presently operating in the space – the social impact of used textile collection is unique to an approach that designates charitable/non-profit as a preferred collector.

Organizations such as Diabetes Canada, Salvation Army etc. utilize the proceeds of textile collection to develop and deliver programs that promote health and well-being for Ontarians.

As an example, in 2018, Diabetes Canada generated more than 10 million dollars from used textile collection, with 100% of those proceeds going into diabetes research and other support programs.

Furniture

Much like textiles, there is no prescriptive legislation for how furniture waste should be managed. In most instances, households bare the physical and financial responsibility for transporting furniture waste to landfills, and will often rely on “junk” collectors to provide this service.

While furniture waste generation is highly variable (depending on locality, season etc.), a review of Ontario waste audits suggests that furniture and white good waste makes up approximately 5% of the overall waste stream, representing approximately 125,000 tonnes of material annually.

However, unlike textiles, end of life furniture does not have a value (or at the very least, it is highly dependent on the item, and site/situation specific factors). As such, collectors have to be financially incented, with the generator (in most cases the household) paying to have items removed and sent to landfill.

Municipalities have traditionally played a limited role in managing these items, but what role can a municipality play in not only supporting keeping these items out of landfills, but maximizing social and environmental outcomes as well?

Charitable Initiatives – The Furniture Bank Case Study

Furniture Bank is a Toronto based charity and social enterprise that helps marginalized and at risk families furnish their homes. Furniture bank accepts gently used furniture and other household items, distributing them to families in need.

This initiative helps divert more than 1500 tonnes of material from Toronto landfills annually, but perhaps more importantly, serves more than 10,000 local clients in need on an annual basis.

In strictly economic terms, the City of Toronto benefits through avoided landfill tipping fee costs (as well as collection costs for large, bulky items), while the province benefits through the provision of a social service to marginalized communities (without incurring a direct cost).

Since 2010, furniture bank has diverted almost 10,000T of furniture/household wares from landfills, which has had an enormous environmental impact for Ontario (shown in figure 3): 

No alt text provided for this image

Given that the vast majority of furniture waste (as noted earlier, in excess of 125,000 tonnes) is ending up in our landfills, there is an enormous opportunity not only to increase diversion rates, but achieve a truly sustainable outcome. 

Leveraging organizations such as Furniture Bank (to serve as a used furniture collector) provides a rare opportunity to address all three pillars of a sustainable waste management program. We are able to increase diversion from landfills (environment), while transferring costs away from local government (economic) and simultaneously support social impact initiatives (social).

As noted earlier, research suggests that Ontarians express a strong desire to support social initiatives and charities through waste donations (used textiles, furniture etc.). In a two year study conducted by York University, households were more than twice as likely to donate their used materials to a designated charitable collector. 

Diversion with a purpose

Waste management (at least in a Canadian context) has historically not been seen through the lens of social sustainability. It is largely seen as a service provided by municipalities, to help keep material out of landfills and promote circularity.

However, as we look to increase diversion rates, we have to ask ourselves two questions: 1) Where will the next diverted tonne come from? And 2) What do I want achieve by diverting more material?

As noted earlier, conventional means and mediums of diversion (i.e. Blue Box) have been exhausted – the next diverted tonne is not likely to come from newsprint or cardboard, but from organics, textiles and furniture.

In addition to finding new opportunities to divert material, what are we trying to achieve by doing so? Is it good enough just to keep material out of landfills, or should we seek to identify ways to maximize economic and social outcomes as well?

This article hopes to highlight that it is possible to “divert with a purpose” – municipalities (and the province) can play a critical role in supporting waste collectors that have a mission beyond “managing waste”, and look to improve the lives and well-being of Ontarians.

The opportunity isn’t just about the hundreds of thousands of tonnes of material not currently being diverted, but the thousands people that benefit through strategic prioritization of material streams and waste collectors.

About the Author

Calvin LAKHAN, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior. Calvin has worked as both a policy planner for the MOECC and as a consultant on projects for Stewardship Ontario, Multi Material Stewardship Manitoba, and Ontario Electronic Stewardship. Calvin currently sits on the editorial board for Advances in Recycling and Waste Management, and as a reviewer for Waste Management, Resources Conservation and Recycling and Journal of Environmental Management

Waste-to-Energy: where now and where next?

, , , ,

Bettina Kamuk, Global Market Director, Waste to Energy at Ramboll

Waste-to-energy is the use of waste to generate energy, usually in the form of heat or electricity. In many ways it is the ultimate in renewable energy, because it recycles what we have already consumed in another form. It is, therefore, a key part of the growing ‘circular economy’.

The idea of the circular economy recognises that there is a limit to the possibilities of recycling. Even recycled goods wear out over time, and further recycling is often not possible. We therefore need a way to deal with the residual waste. We also need a way to deal with waste that is not currently recyclable or recycled. At present, worldwide most of it is sent to landfill. This not only uses valuable space, but also generates methane, a greenhouse gas.

Waste-to-energy offers an alternative—and one with a useful product at the end, in the form of energy. In other words, waste-to-energy has a double bonus for the environment: it reduces greenhouse gas emissions in two ways. First, there are fewer emissions from landfill, and second, it reduces reliance on fossil fuels.

Understanding waste-to-energy

The first incinerator was built in Nottingham, in the UK, in 1874, and the first in the US in New York in 1885. However, these early incinerators usually had little or no capacity to recover either energy or materials. Modern incinerators are able to do both. Many are used to provide heating for local sections of cities. They operate to very tight emission standards so are not polluting, and often reduce the volume of the original waste by more than 95%.

The precise volume, of course, depends on what can be recovered and reused from the ash. Technology to recover metals from ash has developed rapidly in the last few years. A new plant in Copenhagen on the island of Amager, where the Ramboll office is located, is able to recover metal particles as small as 0.5mm across. This is far better than the previous standard of 4mm and is an effective way to sort out metal that is difficult to separate manually before incineration.

Waste-to-energy around the world

At next week’s North American Waste to Energy Conference (NAWTEC), I am going to be part of a panel session on international opportunities for waste-to-energy. The idea of the panel session is to describe what is going on in waste-to-energy around the world, setting out ideas and opportunities for event participants.

Around the world, cities and countries are embracing waste-to-energy, with a number of new green-field facilities being commissioned or built. For example, estimates in Europe suggest that new waste-to-energy capacity of up to 55 mio will be needed to meet landfill directives and circular economy goals. Several Middle Eastern states, including Dubai, Qatar, and Saudi Arabia, have either built or are in the process of commissioning new facilities. New facilities are also being commissioned as far apart as Lebanon, Singapore and Perth, Australia.

In South East Asia, there is a growing move towards waste-to-energy. China’s government has made a decision to move away from landfill, and has already established a number of waste-to-energy plants, mostly using Chinese technology. Thailand and Malaysia also already have waste-to-energy plants. The Philippines, Vietnam and Indonesia have plans to establish plants in the foreseeable future.

Where next for waste-to-energy?

Despite these success stories, there are also parts of the world where waste-to-energy has been slower to grow, such as North America. This is partly because of lack of political will to move away from landfilling, which is perhaps what happens when you have plenty of space. It is also partly because there is less political acceptance that we need to move to a circular economy, with waste-to-energy as a key element. However, as this acceptance grows, there is huge potential in these countries too.

Today a lot of waste is still being sent to landfill or even dumped. The potential for new green-field waste-to-energy facilities is huge. Even in countries where there are already waste-to-energy facilities, old plants will eventually need replacing with modern and more energy-efficient plants. I think the future is bright for waste-to-energy, and I think there is growing acceptance that the future of the world will also be brighter for its increasing use.


About the Author

Bettina Kamuk is Global Market Director and Head of Department at Ramboll. Bettina is a highly experienced waste-to-energy project director and has been responsible for waste-to-energy projects worldwide, most recently in South East Asia and the Middle East. Currently, she is technical advisor for the National Environmental Agency (NEA) in Singapore during the development of the Integrated Waste Management Facility in Singapore planned for an annual capacity of 2 million tonnes of waste-to-energy recovery and more than 200,000 tonnes of bio-waste and recyclables for sorting. Bettina has been Board Member and Chair of the Scientific and Technical Committee for the International Solid Waste Association (ISWA) and has for eight years been chairing ISWA’s Working Group on Energy Recovery.

AboutRamboll

Ramboll is a leading engineering, design and consultancy company founded in Denmark in 1945. The company employs 15,000 working from 300 offices in 35 countries and has especially strong representation in the Nordics, UK, North America, Continental Europe, Middle East and Asia Pacific. Ramboll is at the forefront of addressing the green transition and offers a holistic approach to energy that supports the sector on the journey towards more sustainable solutions. Ramboll has more than 50 years of experience in the planning, design and implementation of energy solutions, covering the full spectrum of technologies and all parts of the value chain from planning to production, transmission and distribution. Ramboll has worked on waste-to-energy projects in 45 countries, providing consulting services for 155 new units and retrofits.