AMDEA response to consultation on the proposed Zero Waste (Scotland) Regulations 2011

28 February 2011

While we support the segregation of food waste and our comments are primarily related to this aspect of the consultation, our members' products are also subject to the WEEE (Waste Electrical and Electronic Equipment) Regulations and it is possible that impending changes to these Regulations will have an impact on Local Authorities. In these times of severe reductions in funding for public services it is important to understand the implications for the domestic waste stream and for consumer attitudes to recycling.

However, in terms of this consultation we have commented on those questions that we feel are most pertinent to our industry: 

RESPONSE TO QUESTIONS 

1. Are there any other materials or waste streams which should be included in these requirements to sort and separately collect?

We would not wish to see an automatic assumption that separated food waste implies a separate kerbside collection as we are concerned that the use of FWD should not be viewed as a secondary method of dealing with food waste.

We are particularly concerned that the drive to reduce waste to landfill should not preclude consideration of waste as a resource. Food waste has value for biogas and fertiliser and its value is enhanced where it can be isolated from other waste streams and contamination.

In terms of maximising waste segregation it is not necessarily helpful to require multiple waste streams to be separated but we would emphasise the necessity for food waste to be separated from otherwise recyclable packaging to fulfill its full potential as a resource.

2. Food waste is required to be presented in a dedicated container. Are there any other recyclable materials which should be sorted and presented separately for collection in a dedicated container?

Again we would argue that food waste does not have to be presented in a separate container if a FWD is used.  Where a dedicated container is supplied the householder needs to understand that it can only take food waste and that the inclusion of other materials (including liners) affects the viability of the segregate for composting/energy extraction.  Likewise packaging made of recyclable materials that is contaminated by contact with food waste should not be included in dry recyclable containers.  This adds a level of complexity to the process of household waste segregation which is yet another disincentive for that householder.  Given that research has also shown that people who live in flats are less likely to recycle at all, it would be unrealistic to specify means of segregation too narrowly.  There is also an issue with oil and fat since householders are unlikely to put e.g. oil or milk into a food caddy and will continue to pour it down their drains to the detriment of the sewage system.  This is also something that FWD can eliminate.

4. Do consultees consider that the Government should mandate more specifically what actions waste collection authorities must take to improve recycling of waste from households? If so, what are they?

In areas with high rise, multiple occupancy and/or properties with no external amenity space it will always be much more difficult for householders to segregate waste.  The Government could recommend different options but the precise options selected by a waste authority need to be flexible.   It should not be the case that reducing waste to landfill outweighs the dictates of public health concerns and in any case a too prescriptive approach risks alienating householders.

FWDs installed under kitchen sinks grind food waste into minute particles that are then transported by the waste water system to waste water treatment works.  In Scotland, 65% of these plants process the waste to produce compost and extract biogas for energy. This technique is particularly suitable for multi-occupancy premises in urban areas.  The benefits in terms of capturing the waste, public health and the avoidance of organic waste rotting in public areas are undeniable.

The Chartered Institution of Water and Environmental Management (CIWEM) has a Position Paper on FWDs which clearly explains the benefits.  We would like to see recommendations to waste collection authorities to encourage the use of FWDs.

5. What additional measures, if any, should Government consider in order to oblige householders to recycle?

A ten year study in Surahammar, Sweden, has shown that food waste disposers are a popular measure and, used as part of a planned combination of waste disposal methods programmed combination of measures, have improved biogas production by 46% and capture of all recyclables by 60%.  In Surahammar residents were offered a choice of measures with a lower rate of tax for households that opted for compost bins and an even lower rate for those that chose to use FWDs - some 50% of households now use FWDs.  Rather than look at measures to “oblige” householders to recycle it would be beneficial to offer incentives for them to do so.

6. Do consultees consider that banning the listed materials accompanied by a “requirement to sort” will be effective in achieving high recycling rates? If not, what additional or alternative measures could be adopted?

No.  Without adequate alternatives a ban cannot be fully effective and the costs of attempting to enforce such bans would be considerable.  In addition, merely imposing restrictions is likely to lead to increased fly-tipping.

It is also worth mentioning that persistent waste contaminants results in 15-20% of food waste sent to anaerobic digestion sites having to be manually separated and re-directed to landfill.  Achieving higher rates of recycling depends on all parties cooperating with is more likely to happen if measures are encouraging rather than prescriptive.

7. Do consultees consider that banning the listed materials accompanied by a requirement to sort will help support investment in the infrastructure required to achieve high recycling rates?

No.

12. Do consultees consider that the lead-in times for the landfill bans are reasonable?

No.  There is no point in setting a target for all food waste to be collected separately by 2013 if adequate recycling capacity will not be reached until 2015.   If in the interim the separately collected food waste is to be sent to landfill this would undermine public confidence in the scheme and lead to increased resistance on the part of householders to segregate their waste.

14. Do consultees have any other comments?

AMDEA agrees that food waste should be a separate waste stream wherever possible.  However the proposals in the consultation are directed towards a single solution which is not only difficult to achieve but also ignores the existence of a highly successful alternative which separates food waste at source.

While only about 6% of UK households have FWDs, many parts of the world have much higher penetration with some cities achieving well above 50% as part of a structured approach to seeing waste as a resource.  Food waste is available for reuse in two distinct ways - the residual matter after processing at a water treatment plant can be used in agriculture and the chemical breakdown of food waste is a source of energy.  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.