AMDEA's response to Scottish Government's consultation on Waste Hierarchy Guidance  

30 November 2012

AMDEA's members are fully committed to reducing waste and encouraging recycling but we have some member companies with a particular interest in the application of the waste hierarchy with regard to food waste as they manufacture domestic food waste disposers (FWDs).

While we support the reduction of waste and recovery of value from all recyclables, where the carbon and financial cost can be proved viable, our comments primarily relate to the management of the food waste stream, and we have commented on those questions that we feel are most pertinent to our industry:


Q1. In your opinion, is the Waste Hierarchy Guidance helpful and easily understood? Does it help you to understand what you need to do to apply the hierarchy when considering waste management options?

This document helps to understand the waste options and criteria established in Scotland. However, as with the legislation, it falls of short of being evidence based. It also fails to keep pace with the latest developments in other EU member states and elsewhere, where food waste disposer technology is being continually trialled, scrutinised for life cycle assessment and adopted to maximise food waste recovery.

Q2. In your opinion, are the material specific guidance sheets clear in terms of their content and messaging? Do you agree with the guidance provided in each ofthese sheets? If not, why?

The documents are clear but limited in scope. As stated previously both Scottish policy and the Scottish Government approach to implementation fall short of a robust evidence base, where they fail to recognise proven alternative solutions for the collection , processing and recovery of value from food waste. The insistence on a single solution for all locations will provoke failures of implementation in certain locations and reduce the success of outcomes in others.

Q4. Do you agree with the evidence and assumptions underpinning the Waste Hierarchy Guidance? Ifnot, why? 

Both AMDEA and CESA challenged the Scottish Government’s assumptions during the legislative process, with regard to the role food waste disposers can play in maximising the resource value of food waste. A range of un-substantiated objections were raised in relation to the sewer network, health, resource conservation and recovery of value; all of which were answered. Despite the submission of independent scientific evidence from various countries contradicting these objections; regrettably this proof was ignored. Extensive work from Sweden demonstrating that FWDs removed potential pathogens from the kitchen, did not damage or block sewers and enhanced recovery of resources of both biogas and soil improver was not taken into account.
This body of positive, authoritative evidence continues to grow as more countries seek innovative and sustainable solutions to the management of this waste stream. It is now enhanced by the comprehensive Danish DANVA 85 study of 2011 (English version attached) . This study was particularly notable as it was undertaken by the Danish Water and Waste Water Authority in collaboration with various Danish local authorities and COWI a leading Danish engineering firm. Denmark has prohibited landfill of biowaste since 1997, but is now actively pursuing an increase in the production of biogas. The Danish study concludes in its opening pages that attitudes to food waste disposers are “based more on emotions and general opinions than on research-based facts.” This study puts forward a number of recommendations with regard to the use of FWD within the Danish regulatory structure and concludes that in some situations, assessments of the working environment, accessibility and other issues may lead to the conclusion that installing food waste disposers is the optimal solution.
In England, this Autumn, the Local Government Association has initiated a pilot study of FWDs in Shrewsbury, Staffordshire, in collaboration with Severn Trent Water. This field study marks the first of a series of English regional FWD research projects that the LGA plans to undertake as part of the Association’s Productivity Programme. This funding programme aims to identify 

innovative, cost-efficient and environmentally sound solutions to enable English local authorities to fulfil their obligations. The programme began with a review of current research, literature and existing practice on the usage of food waste disposal units (FWDs) across the globe. This research found that FWDs mainly have a positive impact on the environment and do not have a negative impact on the sewer network or waste-water treatment works.
The report summarising the findings along with a spread sheet detailing each piece of research reviewed are both attached and are published on:
Scotland should reconsider its stance in the face of this work, evolving evidence and attitudes, particularly in the case of countries such as Denmark that has lengthy experience in the banning of landfill.

Q5. Is there anything else you would like to see included in this guidance?

The guidance adequately covers the regulations adopted in Scotland. On the basis of evidence it appears likely that the unintended consequences of policies adopted, without basis in fact, will emerge as Scotland experiences the limitations to successful outcomes which are prompting other countries to re-evaluate the role of food waste disposers. It would be prudent for the Scottish Government to reconsider its position in this regard and to allow the nation the benefits of food waste dispose as part of a cohesive, compliant, evidence-based food waste management policy..
At a time when Europe is setting aspirational targets for the percentage of energy to be derived from renewable sources, food waste is an important option, particularly as so many water treatment plants are already employing anaerobic digestion, so that much of the basic infrastructure is already in place.