THE GALLON
ENVIRONMENT LETTER
Canadian
Institute for Business and the Environment
Fisherville,
Ontario, Canada
Tel. 416
410-0432, Fax: 416 362-5231
Vol. 17, No. 11, July 31, 2013
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IN
MEMORIAM
Gary Gallon, highly respected and well-known
environmental business leader and founder of the Gallon Environment Letter,
passed away 10 years ago. He will be fondly remembered.
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ABOUT THIS
ISSUE
Ontario was one of the key leaders in Extended
Producer Responsibility in North America with its somewhat less than
satisfactory 2002 Waste Diversion Act. That Act is now up for replacement. Some
of the articles in this issue of Gallon Environment Letter discuss some of the
more general EPR topics and we will return to the subject of Ontario's EPR
challenges in another issue. Extended Producer Responsibility is more than one
province's initiative, or even than all provincial initiatives. In this issue we
look at EPR, what it is, what it means and how it is being implemented
(re-implemented) in Ontario, British Columbia, Quebec, Taiwan, Hong Kong, and
elsewhere. There are lots of interesting ideas coming from Asian EPR programs to
add to those from Canadian experience.
We also take another look at Canada’s
Commissioner for Environment and Sustainable Development's past comments about
transportation of hazardous goods by rail, some available environmental
internships and wage subsidies, and new crops from wild relatives.
In some ways continuing our theme of Extended
Producer Responsibility but perhaps being of greater interest to feeders and
fooders than this issue, our next issue will present green restaurants as a
feature topic. If you have a few minutes spare during the summer we invite you
to send us a letter to the Editor not only on the articles in this issue but on
any business and the environment topic that interests you. Send letters to the
Editor to editor@gallonletter.ca; we will publish a selection of the most interesting
articles received, as long as they are not just blatant advertising!
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CCME:
CANADA-WIDE ACTION PLAN FOR EXTENDED PRODUCER RESPONSIBILITY
In October 2009 Canada's
federal/provincial/territorial environment ministers agreed in principle to
implement the Canada-wide Action Plan for Extended Producer
Responsibility.
Canada was said to lag other G8 and OECD
countries in diversion from municipal solid waste and incineration. Nationally,
waste diversion in 2006 was at 22%, the same as in 2004. Per capita municipal
solid waste was about 1,100 kg per year (Statistics Canada). Many environmental
leaders were proposing that expenses related to the managing the end-of-life of
products should be seen as part of the cost of doing business, the same as other
factors of production, so the price of waste/recycling should be included in the
wholesale and retail pricing. As well as shifting the costs from the public
purse, the aim was also to lessen environmental risks including reduced toxicity
and greenhouse gas emissions.
The Canadian Council of Ministers of the
Environment is an intergovernmental agency formed by 14 member governments
(provincial, territorial and federal). Its Waste Management Task Group oversees
waste management issues including implementation of the Canada-wide Action Plan
for Extended Producer Responsibility: "The purpose of the CAP for EPR is to
extend the principle of producer responsibility across the country in a
consistent and harmonized way with maximum impact across the national
marketplace."
Economic/Environmental Value of
Recycling
Environment Canada estimated that, over the 25
years 2008-2033, 1 billion tonnes of MSW would be generated. Half the waste is
paper, food, leaf and yard waste which together contribute to methane emissions
from landfills. The recyclable material disposed of is estimated to be worth $25
billion (not including the value of compost or energy from waste). With a
disposal rate of 500 kg per capita by 2030, $10 billion would be added to the
Canadian economy through recovery of paper, metals and plastics.
Lasting benefits would be achieved by reducing
waste generation in the first place as well as by diverting from disposal. This
would achieve reduced release of toxic and hazardous substances and reduced
greenhouse gas production. EPR, which would handle certain products separately
from the conventional municipal waste programs through special collection and
recycling systems, is seen as a better way for handling end-of-life products
with hazardous or toxic materials or which pose other problems for waste
management.
Definition of
EPR
The OECD defines Extended Producer
Responsibility (EPR) as: "an environmental policy approach in which a producer’s
responsibility for a product is extended to the post-consumer stage of its life
cycle." CCME elaborates on the definition: "Extended producer responsibility
(EPR) is defined as a policy approach in which a producer’s responsibility,
physical and/or financial, for a product is extended to the post-consumer stage
of a product’s life cycle. EPR shifts responsibility upstream in the product
life cycle to the producer and away from municipalities. As a policy approach it
provides incentives to producers to incorporate environmental considerations in
the design of their products. EPR also shifts the historical public sector
tax-supported responsibility for some waste to the individual brand owner,
manufacturer or first importer."
Definition of
Waste
For EPR, the CCME definition of waste is
municipal solid waste. It includes recyclables, organic and residual materials
from residential and industrial, commercial and institutional sources as well as
construction and demolition waste destined for municipal collection/disposal.
Exempted from the definition are wastes from resource extraction and harvesting,
agricultural wastes, air pollutants, effluents to water from manufacturing or
other processing, nuclear waste, hazardous wastes except household and special
wastes specifically identified, medical and related wastes, gas wastes, gravel
and rocks.
4R
Hierarchy
The EPR program is supposed to follow the 4R
waste management hierarchy:
- Reduce including reduction in toxicity and
redesign to make products more reusable or recyclable
- Reuse
- Recycle
- Recovery of materials and/or energy.
GallonLetter notes that energy from waste is a controversial issue in terms of
product stewardship where recycling is supposed to be of higher
priority.
Performance
Indicators
Key indicators for performance are to be
published in the national annual status report:
- kilograms per capita captured or
recovered
- dollars per kilogram captured or
recovered
- per cent of waste captured
- per cent of waste recovered
- avoided greenhouse gas
emissions.
The CAP itself doesn't set waste diversion
targets but says each jurisdiction should set those. The key performance
indicator for the CAP will be "the number of operational EPR programs and
product categories in place by the commitment target dates. The implementation
of EPR framework legislation and operational programs will be reported on
annually by CCME." GallonLetter looked at the publication list for CCME and
couldn't find an annual report on EPR in the publications list.
Phasing in of
EPR Across Canada
Phase 1 targets EPR programs to be operational
with 6 years ie 2015:
- Packaging
- Printed materials
- Mercury containing lamps
- Other mercury-containing products
- Electronics and electrical products
- Household hazardous and special wastes
- Automotive products
Within 8 years ie 2017, operational EPR are to
cover
- Construction materials
- Demolition materials
- Furniture
- Textiles and carpet
- Appliances, including ozone-depleting
substances (ODS)
If programs for these products already exist,
they should be reviewed to make them consistent with the implementation plan and
goals of the action plan for EPR.
Tools and
Strategies
Because of the geography, infrastructure and
population, EPR may not be suitable for the Territories and other measures may
be more appropriate to achieve the outcomes for the products listed
EPR programs are unlikely by themselves to
achieve significant waste diversion goals. Other initiatives which support EPR
include "eco-labelling; restrictions on toxic substances; recycled content
standards and regulations; green procurement policies; environmental
performance/voluntary agreements and a variety of other potential standards,
bans, landfill gas recovery, guidelines and educational tools."
The plan includes other information including
strategies, elements of a model EPR Program and regulation, E-waste recommended
for EPR, guidance tools, related strategies such as the Canada-wide Strategy for
Sustainable Packaging, reports and tools such as evaluating whether a product
should be under an EPR programs and dealing with free riders (ie producers who
create waste but avoid paying for it).
Challenges of
EPR Discussed in the Action Plan
EPR programs face a number of challenges
including:
- One of the reasons for transferring the
cost to producers is to incentivize a transition to better product design e.g.
disassembly or less toxic materials. Achieving this goal through other
policies may be needed to achieve these aims.
- Only some products are amenable to EPR
initiatives. Organic waste is not because it is usually not easy to identify
the producer although some material such as diapers are identifiable and
commercial organic waste can also be linked to the producer.
GallonLetter thinks that one of the challenges
not adequately addressed in the CCME plan is that some governments, especially
during recessions, see (erroneously in our opinion) environmental issues as
separate and less of a priority than economic issues. It may not be entirely the
fault of politicians either as voters often think short-term too.
Development of
EPR in Canada: Bc Leads
The first Canadian EPR program modelled on
Germany's EPR initiative, the Packaging Ordinance of 1991 which led to the
Duales System Deutschland, was British Columbia's 1994 waste paint program.
Regulations in BC now address:
- Antifreeze, Used Lubricating Oil, Filters and
Containers
- Beverage Containers
- Electronics and Electrical
- Lead-Acid Batteries
- Packaging and Printed Paper
- Paints including Tree Marking Paint
- Pharmaceuticals
- Solvents and Flammable Liquids, Gasoline and
Pesticides
- Tires
In 2009, there were 40 EPR programs in
Canada.
State of Waste
Management in Canada
One of the issues of setting targets for waste
diversion is that there needs to be a baseline. A number of municipal
jurisdictions have conducted the occasional waste characterization study to find
out what materials in sample loads end up in landfill. CCME is commissioning a
study on waste management in Canada including trends, best management practices,
barriers and opportunities for waste prevention, reduction and diversion in
Canada.
Paid subscribers see link to
original documents and references
here.
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SUCCESS FOR
THOSE WANTING TO SCRAP (DON'T RECYCLE) ONTARIO'S WASTE DIVERSION
ACT
“The WDA has failed consumers, the economy and
our environment,” said Peter Hargreave, Director of Policy, Ontario Waste
Management Association (representing private and public sector members) in a
joint press conference with the Recycling Council of Ontario in April 2013. The
press release described the existing Waste Diversion Act as lacking
"accountability, transparency, oversight, and effective enforcement mechanisms."
Focussing on the results rather than spending so much time and money on
tinkering with programs would allow individual producers to achieve recycling
results with the least cost to consumers. The new EPR legislation should
include:
- Put responsibility on individual companies
and get rid of agencies which allow producers to outsource both costs and
responsibilities. Producers can then innovate and compete.
- Recycling costs should not be added at the
checkout; they are part of doing business.
- Government should set the standards and the
targets and enforce them with penalties.
Both organizations have been involved in waste
management policy for a long time so perhaps it isn't surprising that they are
prescient or perhaps have good relations with the Environment Ministry as
Environment Minister Jim Bradley introduced the Waste Reduction Act to replace
the Waste Diversion Act with first reading June 6, 2013. Public consultation on
the Environmental Registry is until September 4, 2013.
The ministry's web site includes a
backgrounder with support quotes from various people including from RCO and
OWMA:
"The proposed Waste Reduction Act is
forward-thinking policy that has clear benefits for Ontario's environment and
taxpayers: increased waste reduction and recycling targets, enforceable
standards, and improved accountability that focus on results will position
Ontario as an environmental leader. These improvements allow and encourage
companies to innovate and invest in Ontario's recycling industry, and keep
valuable materials from disposal."
- Jo-Anne St. Godard, Executive Director,
Recycling Council of Ontario
"Minister Bradley, who led the charge to
increase diversion in 1980s, has set Ontario back on the right path to increase
waste diversion, support green jobs and investment, and ensure the efficiency
and effectiveness of waste diversion that comes with competitive and open
markets."
- Rob Cook, CEO, Ontario Waste Management
Association
Paid subscribers see link to
original documents and references
here.
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ONTARIO WASTE
MANAGEMENT ASSOCIATION: POLICY POSITION ON EPR
The OWMA provides several reviews of the new
Waste Reduction Act on its web site which it says supports many of the views
expressed in the OWMA's policy paper on Extended Producer Responsibility issued
in June 2013 and expressed in the past. Among the observations are:
- Recycling costs should not be added at the
checkout but be included in the price of the product. Recycling is a business
cost.
- Companies should be given flexibility in how
to achieve the province-wide enforceable outcomes and standards set by
government; outcomes should be quantifiable and measurable.
- EPR cannot exist without competitive
marketplaces. Industry stewardship product groups can create monopolies which
just pass on costs to consumers through ecofees which prevent the business
from internalizing the cost which would motivate them to innovate and increase
program efficiencies.
Producers should be individually responsible
and while they can get help from a collective should have flexibility to choose
how to achieve the outcomes as long as they comply with the standards set by
government. They should have to file an annual report
Extended producer responsibility is an
economic/environmental instrument making producers of packaging and products
responsible for the costs (environmental, physical handling and financial) of
the end-of-life of the product instead of making tax-supported municipalities
responsible.
Individual/collective
Responsibility
The producer can be individually responsible
for their own products, ie this is polluter pay as the producer only pays
the amount related to their own products. There could still be a collective
collection system. In Collective Producer Responsibility, the program allocates
costs by market share. With no payback for better design, some say that this
model doesn't incentivize companies to improve their products. The OWMA paper
suggests that some schemes known as product stewardship programs aren't EPR but
just a form of taxation because the manufacturers or importers don't have any
other responsibility or liability. The policy suggests that IFOs (Industry
Funded Organizations) set up monopolies.
Changes Needed
for Waste Diversion in Ontario
OWMA's paper sets out some of the changes
needed from how the WDA works:
- The government should set clear outcomes
which can then be met in an open and competitive marketplace. Otherwise, the
government may tilt the functioning of the marketplace towards existing
industry funded organizations which gain unfair competitive advantage.
Enforceable outcomes include environmental standards such as for collection,
transport and processing, service standards such as accessibility, targets
such as reduction, reuse, recycling and recovery, administrative penalties for
non-compliance and timelines. Once the standards are set the government should
let companies innovate and compete.
- Expanding EPR can affect the current
infrastructure and the local economy as municipal collection is impacted with
changes such as different collection methods, contractors, service
levels.
- Consumers need more choice in how the
programmes are delivered and be able to impact product design by their
purchasing. Standards should require adequate service levels including
geographic accessibility with appropriate penalties if the outcomes aren't
met.
- Governments should understand the markets
before regulating e.g. what infrastructure may be lacking for collection and
processing, what and where the end markets are; what other regulations are in
place and what competing interests are. Waste related data is often scarce.
Data is needed to assess whether EPR is the right instrument. For example, old
vehicles, white goods and used oil have value so that EPR for these products
isn't really a good idea as there is already a working market.
- Less emphasis should be on the plan which
results in too little flexibility, lack of standards and no consequences for
under performance. More emphasis should be on the performance and outcomes of
the program.
- Waste diversion targets should be realistic
with separate targets for separate waste streams (e.g. ICI vs residential)..
Ontario generates 12.5 million tonnes of waste per year; the ICI sector
creates 60% of the waste and the residential sector 40%. Overall only 25% of
waste is diverted which hasn't changed much over the last couple of decades.
The rate of diversion of the ICI sector has decreased averaging around 13%
while the residential rate is around 37%. Too low targets don't encourage
investment and innovation. Targets should be aggressive targets and continuous
improvement should be required. Companies making best efforts to divert are
put at competitive disadvantage by lack of government enforcement which allows
others to claim they are diverting when they are simply disposing of
waste.
Paid subscribers see link to
original documents and references
here.
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ECO: ONTARIO'S
WASTE: FINALLY MOVING FORWARD
Despite decades of posting progressive and
effective notices on the Environmental Registry on waste reduction and
diversion, "the ministry has not made any real progress on this file", until
now, says the Environmental Commissioner of Ontario.
MOE seemed to be on track when posting in a
2008 review of the Waste Diversion Act a discussion paper, Toward a Zero Waste
Future and in 2009, From Waste to Worth: The Role of Waste Diversion in the
Green Economy both posted on the Environment Registry for public discussion.
This last focussed on individual producer responsibility. Gord Miller wrote in
his blog, "But then, on July 1, 2010, the garbage hit the fan. That was the day
that MOE’s municipal hazardous or special waste (MHSW) program was expanded to
include 13 additional categories of household hazardous waste (including
rechargeable batteries, fire extinguishers, fluorescent bulbs, etc.). Because
inclusion in the program meant that producers of these products had to pay
stewardship fees to cover the costs of managing them at end-of-life, some
retailers started adding a separate “eco fee” line to their receipts, presumably
in anticipation of these fees being passed on to them by producers (and also,
presumably, to indicate to consumers the source of these new costs).
Unfortunately, these retailer-imposed fees created widespread confusion and
anger that a “recycling tax” was being imposed by the government, and the
negative media and public outcry led the government to withdraw the expanded
program, transferring the costs of managing these wastes from producers back to
taxpayers (for more information, see my Special Report on “eco fees” and the
expanded MHSW program). Suddenly, waste diversion and producer responsibility
became political hot potatoes, putting on hold MOE’s plans to fix the broken
waste diversion system."
Miller notes that there is no such things as
eco fees or new taxes set by the government as it is the stewardship groups that
set the fees. In some cases, in July 2010 retailers like Canadian Tire which
seemed to be the most profiled retailer in the media were charging "eco fees"
that were higher than any of the fees producers were to pay through the industry
funded organization IFOs. Other retailers like Shoppers Drug Mart didn't charge
the fees at the time due to uncertainty of what to charge. The Ministry of the
Environment was the prime target of consumer/media ire; in August, 2010,
Environment Minister John Gerretsen was shuffled out of this ministry with
headlines such as in the Toronto Star, "John Gerretsen demoted over eco fee
fiasco". GallonLetter notes however that the fiasco reflected very badly on
industry as well with later commentary seeing the industry funded organizations
as negative market forces, skewing the market through monopolistic activities
which lead to costly and inefficient recycling charged indiscriminately to
consumers with insufficient accountability and not enough oversight by
government.
In 2012, the Commissioner convened a meeting
of 30 stakeholders to develop a framework for the revision to the waste
diversion laws and he sees the proposed Waste Reduction Act as "lifting the fog
of inaction" and finally moving forward: "Amongst other things, the proposed
Waste Reduction Act would establish IPR requirements, ensure consumer protection
by prohibiting surprise “eco fees” at the register, require producers to
reimburse municipalities for the costs of collecting and handling products at
end-of-life, and install a Waste Reduction Authority to oversee the compliance
and enforcement of the new IPR regime. The ECO hopes that the Legislature uses
this as an opportunity to debate waste reduction solutions and finally make
much-needed progress on this important issue."
Paid subscribers see link to
original documents and references
here.
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ONTARIO TIRE
STEWARDSHIP: ANOTHER BACKLASH ON SEPARATE AND RISING RECYCLING
FEES
Scrap tires in Ontario are managed under the
industry-funded Ontario Tire Stewardship OTS which sets a sliding scale of fees
charged when new tires are purchased.
OTS, one of the four provincial recycling
programs under the current Waste Diversion Act WDA (2002) is governed by brand
owners and importers known as the stewards, administrating the program since
2009. For example, among the directors on the OTS Board are:
Sarah Webb, Manager, Product &
Environmental Stewardship at Canadian Tire Corporation
Usman Valiente, Director, Environmental
Affairs, Ontario Tire Dealers Association
Joelle Assaraf, Director of Commodity Tax at
Costco Canada
The new Waste Reduction Act provides for the
four existing IFOs to continue into a transition period which Andrew Horsman,
Executive Director of OTS suggests is expected to end 2017. A lot of space in
the new Act relates to winding up these IFOs with exemptions for the Brewers
Retail. Inc. and quite a few sections on enforcement. However, the Ministry can
only enforce the law so much of the impact depends on the regulations which may
designate waste as being a product, any part of a product, a container or
packaging, or any combination as well as defining waste classes. A producer is
described as a person who manufactures the products, owns, licenses or has
rights to the product, sells the product to a person in Ontario, imports the
product into Ontario, has rights to the brand or has a commercial connection and
who meets the conditions including specified activities to be specified in the
regulation. GallonLetter thinks much depends yet on the devil in the details.
While EPR laws are often interrelated with other laws, as EPR policies develop,
regulators can learn from each other. For example, even though, we all think we
know what packaging is, the courts may not agree. For example, a decade or so
ago, the UK Environment Agency sued a horticultural producer because it was not
participating in producer responsibility for packaging in relation to plant pots
but the court decided that a plant and its pot cannot be separated: a plant pot
was deemed not to be packaging.
GallonLetter notes that some say that this new
proposed Act will get rid of free riders (those producers who sell product and
don't pay) but there are always gaps, what are called orphans (products not
allocated to any existing producer) and historical waste. To a considerable
extent, OTS now collects all kinds of tires including those dumped into public
spaces. If the producers pay only for the recovery of the same number (and type)
of tires they put into the Ontario marketplace (they don't actually have to
collect their own tires but are in compliance if they collect designated waste
in that waste class), historical waste may still be an issue. Whatever it is, it
could be a big change. "I think it's a paradigm shift," said Michael Blumenthal,
VP of the Rubber Manufacturers Association quoted in Rubbernews.com. "If this is
enacted, it means Ontario will go from a completely subsidized scrap tire
program to a free market program in two years."
Farmers
Protest Spring Hikes in Tire Recycling Fees
Ontario, unlike some other EPR programs
elsewhere does not exempt tires used for off-road vehicles so in Ontario, farm
equipment tires and other tires have been included. A new fee structure was
implemented in April 2013 by OTS based on weight instead of diameter and use.
The OTS proposal for the fees raised farmer outrage. Fees for common tires were
to be raised from $15.29 to a range of $29.40 to $47.04 while the maximum fee
was raised from $250.20 to $1,311.24. In response to lobbying by farm
organizations like the Ontario Federation of Agriculture, the OTS fee schedule
was amended to class tires up to up to 250 kg in the under $47.04 category and
all tires over 250 kg at $182.28. If farmers purchase tires from outside
Ontario, they are still responsible for paying the stewardship fee to
OTS.
OTS is using some of its funds to research use
of recycling tire material in such products as landscape and playground tiles,
shingles and mulch, stall mats for cows and horses.
The shift to individual producer
responsibility and the removal of the mandatory fees is seen as a fundamental
shift in the organization of how tires are recycled in Ontario. OTS says it has
overseen the recycling of 50 million tires at a rate of more than 95% or as
Andrew Horsman, Executive Director of OTS says, "This phenomenal success is a
result of our collective commitment to diverting tires from burning and
landfills, and is a testament to the effectiveness of the Ontario tire recycling
industry."
Paid subscribers see link to
original documents and references
here.
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ENVIRONMENT
CANADA: EPR INVENTORY
Environment Canada has an inventory of
Extended Producer Responsibility and Product Stewardship Programs (web site has
date 2012-07) which includes:
- what products are part of the program
- the collection method and information source
for drop-off location
- targets and performance
- how fees are applied
- policies, monitoring and reporting
- contact for more information.
The search menu covers national, provincial or
territorial and product categories which are:
- automotive products
- beverage containers
- electrical and electronic equipment
- household hazardous waste
- mercury containing products
- packaging and printed materials
- pesticides and containers
- pharmaceuticals
- refrigerants
Paid subscribers see link to
original documents and references
here.
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BC: PACKAGING
AND PRINTED PAPER EPR
Brand owners and first sellers that introduce
packaging or printed paper (PPP) into the British Columbia residential market
must submit a stewardship plan or be part of a plan submitted to the BC Ministry
of Environment by November 19, 2012 and implemented by May 2014. The BC program
is the first industry-managed full EPR packaging and printed paper program in
Canada. With deposit return, depot and curbside recycling, about 50 to 57% of
this material is being currently collected. Glass containers, some of which are
covered by deposit return as well, are no longer going to be collected curbside
but will be accepted at depots; some municipalities oppose and others have
already implemented the removal of glass from curbside collection. The
regulation relates to residential waste although the Ministry is considering
whether to expand to ICI sectors. As with most of the BC EPRs, some of which
also have targets for subcategories, the mandated recovery rate is
75%.
MultiMaterial BC MMBC: the non-profit
organization overseeing collection services for the new British Columbia's EPR
for packaging and printed paper is changing the word of companies obligated to
be responsible for their end of life products to “stewards” to reflect the
environmental part of the responsibility and their obligations under the MMBC
stewardship program. MMBC submitted its plan three times and got approval for
its April 9, 2013 plan as it relates to materials and products listed in Section
5 of the Recycling Regulation. All the stewardship programs in BC are covered by
the single Recycling Regulation with new products added as amendments with the
addition of a schedule for a particular material or product category. A list of
BC's products with industry stewardship is at http://www.env.gov.bc.ca/epd/recycling/. Companies can also set up their own management of their
end-of-life products.
MMBC's Board
of Directors
MMBC's Board of Directors includes Retail
Council of Canada, Food and Consumer Products of Canada, Canadian Federation of
Independent Grocers, Canadian Restaurant and Food Services Association, Loblaw
Companies Limited, Overwaitea Food Group, Tim Hortons and McCain
Foods.
Achieving the
75% Recovery Target
To achieve the target, MMBC plans
to:
- expand on existing residential collection
such as curbside, multi-family residents and depot
- expand recycling curbside collection to
residents served only by garbage collection
- expand the type of packaging and printed
paper collected
- use collection in parks, sidewalks, plazas
and other away-from-home collection
- work with partners for efficient collection
systems for residences.
Accessibility of residents to recovery
programs is an important issue e.g. number of depots within a certain distance
or number of households served by curbside collection. GallonLetter sees
switching from curbside to depots as a reduction in service. While in theory, if
a person can buy it and bring it home, the same person should also be able to
take it to the depot, in practice several things make it difficult. For one
thing, the nature of the product changes when it is used much like that nice
tidily bundled Christmas Tree becomes a mess of dropping needles. Even empty
bottles have been known to contain liquid which stains the car seat. For another
thing, depots are often in different places from where the product is bought
(see separate article on Taiwan which requires depots at 14 retail outlets where
take-back products are sold). So a senior might be able to walk to the local
store to buy a product but can't easily get to the depot especially if a number
of items have to be carried to be returned. Some consumer combine trips to
depots with regular shopping but many people might make special trips just to
get rid of stuff increasing the energy costs associated with transportation of
recyclables.
Producers
Among EPR models are different definitions of
which companies are obligated to participate. In this case, the differentiation
is based on whether a producer is considered to have residency in
BC. Residency includes an office, workshop, warehouse, factory, any fixed
place of business including a home office, land ownership. If employees or
agents of the company are located in BC and can sign an order that would bring
in stock even if that comes from elsewhere, that is residency. An insurance
company registered in BC has residency. Any physical activity such as
manufacturing, packaging, mining, growing, creating or constructing in whole or
in part has residency.
Non-residency includes those with only a BC
Post Office box. If a company has only agents receiving a commission rather than
some regular form of compensation it has no residency. A parent company with no
permanent establishments isn't obligated but it may have a subsidiary
that is resident. When the only purpose of the company office is to purchase
merchandise it is not considered resident.
Once considered to have residency, a company
is obligated if it
- supplies packaging or printed paper into the
BC residential market. Residences include single and multi-family buildings
including seasonal, time-share (but not at places such as ski resorts which
are commercial), coops, senior residences if not providing medical care. Also
included is municipal property which is not institutional, commercial or
industrial e.g. sidewalks, town squares, and municipally owned parks
and
- is a brand owner, first importer or
franchiser of packaging or printed paper
Producers are expected to pay including the
administration costs, education of residents to promote collection and material
management at collection and post-collection. Fees also cover research and
development to overcome technical and market capacity barriers.
Producers will be expected to provide data on
such things on what their products are and in which packaging, the quantity
supplied to BC residents, types of materials, weight of each materials used,
types of printed paper and quantity supplied.
Packaging and
Printed Paper
The definition of packaging is from the
Environmental Management Act and includes primary packaging for the residential
customer and grouped packaging that goes to the household e.g. water bottles
wrapped in film plastic, transportation, distribution or tertiary packaging that
goes to the household e.g. if product is packed in cardboard boxes taken home,
and service packaging designed and intended to be filled at the point of sale
and “disposable” items sold, filled or designed and intended to be filled at the
point of sale such as:
a. Paper or plastic carry-out bags provided at
checkout
b. Bags filled at the shelves with bulk goods,
produce, baked goods etc.
c. Disposable plates and cups
d. Take-out and home delivery food service
packaging such as pizza boxes, cups, bags, folded cartons, wraps, trays
etc.
e. Flower box/wrap
f. Food wraps provided by the grocer for
meats, fish, cheese, etc.
g. Prescription bottles filled and provided by
pharmacists
h. Paper envelopes for developed
photographs
I. Gift wrapping/tissue paper added by the
retailer
Also included are packaging components and
ancillary elements integrated into packaging, including ancillary elements
directly hung or attached to a product and which perform a packaging function unless they are an integral part of
the product and all elements are intended to be consumed or disposed of
together. Examples include labels, lids, brushes carried by the lid e.g. brush
for liquid paper, staples, clips, measuring cups part of the lid, plastic
make-up case, zipper on plastic bag. Paper includes paper made of a variety of
material such as bamboo.
Printed paper includes telephone directories
but not bound books such as reference, library or text books.
GallonLetter notes that these definitions are
rather important as they affect the range of companies affected e.g.
restaurants, drug stores and fast food shops.
Collectors
Collectors must qualify by meeting specific
standards. MMBC will provide financial incentive to local governments and First
Nations communities and if these jurisdictions don't accept, will set up a
separate PPP curbside collection service. For private companies operating
multi-family collection services, MMBC will also provide public education,
promotion and management of collection service. Incentives will also be offered
for depots for single and multi-family residences. Collectors must provide free
access to residents. If PPP is also collected in organic waste collected by
local governments, MMBC will provide a "market-clearing price" financial
incentive to account for the amount of PPP in the organic waste but if the offer
is refused won't undertake to collect organic waste.
The market clearing price which is only for
collection not post collection activities is a subject of some controversy as
some question what the meaning of it is. It is defined as the price at which the
market will supply the services required by the agreement with MMBC for most
efficiency such as reducing costs to below the price. Price might be set at a
flat rate per tonne, household served or some other means to maximize the amount
of PPP diverted from garbage.
Processors
Contracts between processors and MMBC will set
minimum processing system efficiencies including qualification
standards.
Education and
Public Reporting
The Recycling Regulation requires a resident
education program. MMBC's plan outlines a communication plan. The organization
will also compile data on indicators and report annually including greenhouse
gas emissions. The regulation requires third party assurance of the annual
report.
Product Life
Cycle Management
Producers which are members of MMBC are to
contribute to reducing the environmental life cycle of the packaging and printed
material including:
- reduction though use of refillable packs or
reformulating the product to reduce packaging e.g. concentration.
- redesign e.g. through lightweighting or
though use of renewable materials such as bamboo or sugarcane especially to
replace polyvinyl chloride which contaminates other plastics for recycling.
Use of 100% post-consumer resin; sustainable sourcing such as Forest
Stewardship Council certified paper or from sustainably managed
forests.
- improve recyclability e.g. making the cap of
the same plastic as the bottle, removing coating from the carton to make it
easy recyclable. Improve ability of consumers to get the "last drop" out of
containers to reduce contamination
GallonLetter thinks this is one of the weaker
links in the EPR effects because the cost of recycling is still relatively small
compared to the value to the brand of design features which may include
multi-materials difficult to recycle.
Pollution
Prevention
The PPP plan outlines activities MMBC will
undertake to ensure recovery is subject to the Pollution Prevention
Hierarchy:
- Reduce the environmental impact of producing
the product by eliminating toxic components and increase energy and resource
efficiency
- Redesign the product to improve reusability
or recyclability
- Eliminate or reduce the generation of unused
portions of a product that is consumable
- Reuse the product
- Recycle the product
- Recover material or energy from the
product
- Otherwise dispose of the waste from the
product in compliance with the Act
Paid subscribers see link to
original documents and references
here.
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QUEBEC:
PRODUCER RESPONSIBILITY FOR DISPOSAL AS WELL AS RECYCLING
One of the problems with the focus on charging
fees for end-of-life of recyclable products is that it is often cheaper to send
stuff to garbage. In some cases, the fees for recyclable products have had
perverse results e.g. redesigning packaging so it doesn't qualify for the blue
box and the associated stewardship costs. Quebec's updated residual materials
management includes a brief discussion on the goal of reducing residual
materials, "despite major recovery and reclamation efforts, too many residual
materials are sent for disposal. To counter this problem, the government intends
to take measures to discourage the disposal of residual material and avoid the
waste of resources." From GallonLetter's reading the plan is a little short of
concrete action but one of the items is to increase disposal fees and to further
raise fees if that doesn't work. Although waste incineration is allowed new
waste incinerators over 2 metric tons an hour must comply with what is called
4R-D hierarchy and recycling goals and must recover energy generated by
combustion. 4R-D is
"To ensure that residual materials are subject
to the most sustainable management methods, any waste management plan or program
developed by the Minister will give priority to source reduction and, in
treating these materials, will respect the following order: reuse, recycling
(including by biological treatment or landspreading), any other form of
reclamation by which residual materials are treated for use as a substitute for
raw materials, energy production, and disposal. However, deviating from this
order will be possible when an analysis demonstrates this is justified based on
a goods and services life cycle approach." Energy performance, greenhouse gas
balance, final destination of waste and compliance with air emission standards
are part of the criteria.
Greater responsibility for producers
especially in regard to packaging for recycling are to be put in place. Where
producers of containers, packaging and written media used to pay 50% of the net
costs borne by municipalities, companies will be expected to assume the full
cost and over time assume full responsibility for managing the program. Quebec
is said to be the first province to charge 100% of costs to producers beginning
in 2013 for certain specified products. under the amendments to the Environment
Quality Act. ie for containers, packaging and printed material collected
curbside by municipalities. The fees rose over three years from 50% to 70% in
2010, 80% in 2011 and 90% in 2012. In addition, contribution to Recyc-Quebec for
its management separate from the compensation to the municipalities increased
fees about 4%.
Magazines were added to the printed matter
class which changed from 20% to 30% of costs. Other cost increases included a
10% increase in net costs of curbside recycling and another 10% for the
establishment of a Risk Fund to deal with the risk of under estimating the
actual costs.
These costs are much higher than in Ontario
where industry has paid 50%. Quebec has a different distribution of costs among
materials e.g. Ontario allocates about 5% of costs to printed material while
Quebec's is six times that at 30%.
Where products are less suitable for curbside
collection because of their hazards, size, weight or reclamation potential,
producers are more able to find end-of-life management solutions. Extension of
producer responsibility is to include new product categories such as electronic
products, batteries, mercury lamps. Phase Two of Quebecs' Environment Quality
Act Regulation Respecting the Recovery and Reclamation of Products by
Enterprises c. Q-2, r 40.1 covers primary and rechargeable batteries as
components of other products starting July 14, 2013. Batteries sold separately
were in Phase One implemented July 14, 2012. Enterprises can set up their own
individual recovery and reclamation or join Call2Recycle which is the official
battery program operator by Recyc-Quebec, the Quebec government
agency.
Producers can also redesign products to be
more environmentally friendly..
A key performance indicator will be kilograms
of disposed waste per capita.
Over 40% of residual materials in Quebec are
produced by the industrial, commercial and institutional ICI sector with half of
that waste ending up in landfill. Materials such as wood, drywall, metals,
asphalt shingles, carpets, insulation and cardboard often end up at disposal
sites. Increased fees for disposal of these products and ban on organic
materials are seen as a way to change how the two sectors ICI and CRD handle
waste. Some of the fees collected may be used to help develop technologies and
methodologies to make recycling more efficiency.
If outside-the-home collection of beverage
containers can be made as effective as residential curbside collection, the
government is considering get rid of deposit return for soft drinks. Because
beer bottles are refilled, a deposit will remain on those even if the deposit on
soft drinks is eliminated.
Northern communities may be treated
differently because of distances and other factors.
Paid subscribers see link to
original documents and references
here.
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EPR CHANGES
THE WASTE MANAGEMENT SECTOR
"Emerging extended producer responsibility
("EPR") program may impact our customer relations and revenues" according to the
Progressive Waste Solutions (BFI Canada and others) Quarterly Report (March
2013). More jurisdictions in Canada and the US are implementing or are
considering legislation or regulation which could affect the company's
contracts. Among the observations are:
- EPR sets minimum targets for diversion. More
diversion reduces waste volumes.
- Existing contracts for collecting and
processing recyclables could be lost as responsibility shifts to industry-led
stewardship organizations. Even if the contracts continue, the terms may
change as the design such as collection for recycling, transfer and processing
change.
- Stewardship organizations are likely to
organize recycling to achieve economies of scale compared to current contracts
which tend to be issued by various municipal jurisdictions.
BFI's report suggests that one approach is for
the company to join or partner with stewardship organizations to be better able
to provide services producers need. GallonLetter notes that the issue of serving
multiple interests possibly in conflict with each other has been a criticism
levelled at industry-funded stewardship organizations and some of the people who
are providing expert or administrative services serving several masters. In many
of the environmental service sectors, it is difficult for consultants not to
work for a number of different clients but it is an issue that needs to be
considered.
Paid subscribers see link to
original documents and references
here.
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US LAWSUIT BY
PHARMACEUTICAL INDUSTRY: BACKLASH BY INDUSTRY
California's Alameda County ordinance on
pharmaceutical EPR which was to come into effect July 2013 notes that in the US
no federal or state legislation requires medicine take-back even though various
bills have been proposed. And the producers haven't offered any support for a
collection program to date. Canadian examples are given in support ie British
Columbia requiring manufacturer-funded drug collection since 1996, Ontario in
2010 and Manitoba in 2011. Other countries such as France, Spain, Portugal and
others are also mentioned as having manufacturer-funded drug collection
programs.
Even where jurisdictions don't have
manufacturer-paid collection, other collection of medicines is sometimes offered
as is the case in Alameda. For example, hazardous waste days may accept
medicines, the jurisdiction may have special collection days for
pharmaceuticals. GallonLetter notes that in Ontario, the web site of the
medicine stewardship program says pharmacies accept return of medicines. The web
site allows consumers to search for local pharmacists who are expected to take
back leftover medicines. The one time we tried this with a very small number of
vials, the pharmacy was very reluctant although they did accept them. We weren't
sure that the drugstore was really going to see that they were recycled rather
than just thrown in the garbage.
EPR programs for medicines vary in what is
accepted. The Alameda County Safe Drug Disposal Ordinance would not cover
vitamins and supplements, herbal remedies and homeopathic products, cosmetics
soaps, sunscreens, lip balm, antiperspirants, and other personal care products,
pet pesticide products, nonprescription drugs, medical devices, component parts
or accessories even if the device contains a covered drug.
The ordinance has been put on hold due to a
lawsuit with one of the plaintiffs Pharmaceutical Research and Manufacturers of
America (PhRMA) whose lawyers indicate that a lawsuit would also be launched
against King County where the Board of Health called for rule on medicine
take-back in June 2013. The lawsuit claims that the rule infringes the
Constitution which contains a Commerce Clause which prohibits shifting costs of
a local program to manufacturers in other states.
Paid subscribers see link to
original documents and references
here.
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TAIWAN: EPR TO
REDUCE WASTE
Taiwan is a highly populated country in a
relatively small space, said to be the second most densely populated country in
the world (2007). In the 1960s and 1970s. Taiwan was economically underdeveloped
with average income per capita under $2000 with little environmental protection.
Before 1984, waste was often just dumped in open space with only 2.4% ending up
in landfill.(Who would have thought that a low percentage going to waste
disposal could be a negative - just goes to show care is needed interpreting
waste statistics.) This dumped waste known as "Stacked-Up" created serious
health and environmental problems. After a six year plan beginning in 1984 and
with subsidies for local government to build landfills, 179 landfills were built
and disposal of garbage increased from 2.4% to 56%. All those landfills were
taking up valuable space so a new guideline was developed for incineration
first, landfill as an alternative. By 2002, 19 large scale incinerators were
handling 48% of the disposal. About 93% of waste ended up in garbage
disposal/incineration instead of being stacked-up in streets and any available
space.
The next phase focussed on minimization of
garbage through recycling and reuse. A 2012 government press release celebrating
the 25th anniversary of the Environmental Protection Administration said that
the average daily weight of waste per citizen slashed from 1.14 kg in 1997 to
0.43 kg in 2011 and waste recycling rate increased from 5.87 percent to over 60
percent, "making Taiwan one of the world's leaders in reuse management. This was
a miracle in terms of environmental protection." The government committed to
"transforming Taiwan into a low-carbon and high-recycling
homeland."
4-in-1
Program
Taiwan, like Canada, has a plethora of local
and other jurisdictions which make waste management regulation complicated. But
unlike Canada, Taiwan has a national regulation for certain products. The
national program uses a single logo to indicate which products are regulated for
recycling, a very beneficial education tool as the consumer just needs to look
at the product for the 4-in-1 logo, which is a square with 4 recycling arrows,
to know whether it is regulated for recycling.
In 1997, manufacturers and importers were
required to pay fees for garbage disposal and clearance. Regulated recyclable
waste RRW is divided into categories with a specified number of items in each
category. Each recyclable waste has a channel for recycling such as local
government agencies, mandated depots set up by retailers and private recyclers.
A number of other items not regulated such as waste paper, used clothing and
additional metals are collected for their value in recycling and reuse. Later
amendments to the legislation requires businesses to recycle and reuse renewable
resources.
Other regulations cover other aspects of waste
e.g. general waste includes other waste which can be recovered such as food
waste, bulk waste, and general recyclable waste but within the General
recyclable waste is RRW (Regulated, Recyclable Waste) which covers 13 categories
in the 4-in-1 program:
- Iron container (steel cans)
- Aluminum container
- Glass container
- Paper container
- Plastic container
- Pesticide container
- General battery
- Automobile / Motorcycle
- Tire
- Lead-acid battery
- IT equipment
- Household appliances
- Fluorescent lamp
The manufacturers and importers of new RRW or
raw material have responsibility for collection, transportation and recycling
for products and containers. Retailers bear responsibility for collection and
transportation.. Those who pay into the recycling fund get a subsidy for the
value of the recycled material which is said to provide an incentive to design
for recycling. The subsidy is based on certified quantities.
The public EPAT (The Resource and Recycling
Management Fund) decides on the fee rate. Auditing of manufacturers and auditing
and certification of collectors and recyclers is part of the
legislation.
Reasons for including products as RRW
are:
- difficult to transport or to recycle
- contains a component that does not readily
decompose over a long time
- contains a component that is hazardous
- is valuable for recycling and
reuse
The recycling fund
- subsidizes licensed RRW collectors and
recyclers
- grants for collection and recycling
system
- funds municipal RRW collection
- covers management costs such as auditing and
certification
- provides grants to citizen groups promoting
recycling and providing education.
Take Back
Collection Facilities
The law requires that 14 types of businesses
provide collection facilities including supermarkets, convenience stores,
cleaning and cosmetic retailers, light bulb retailers, fast food restaurants,
gas stations, packaged beverage vendors in gas stations, wireless communication
equipment retailers, photographic equipment retailers, home appliance retailers,
vending machine and "chain store of drinks".
The logo is used on the collection containers
as well so consumers know where to put the products.
Taiwan's waste management has many challenges
including the problems of disposing of so much fly ash and other hazardous
waste, illegal dumping, political and other conflicts-of-interests working
against enforcement, waste transport in the congestion of very dense cities.
Taiwan also is trying to include the smaller businesses into the waste
management approach as there is a history of many small companies used to
scavenging and difficult to regulate.
Paid subscribers see link to
original documents and references
here.
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HONG KONG
PLAN: ACTION FOR WASTE REDUCTION USES ASIAN CITY MODELS
The example of other Asian cities in achieving
very good results in waste reduction informs the Hong Kong plan for sustainable
use of resources to 2022 released May 2013 which says, "Their experience tells
us that Hong Kong can do very much better if we take coordinated and
simultaneous action on waste prevention, reuse, recycling, recovery, treatment
and landfilling, as part of a whole resources management chain. Hong Kong has
fallen behind because we have only taken some of the steps. We need to urgently
fill in the gaps." HK's target is to reduce per capita MSW disposal rated from
1.27 kg per day in 2011 to 1.0 kg by 2017 and to 0.08 kg or a 40% reduction by
2022.
Among the challenges are:
- public distrust that waste collectors
actually recycle material rather than dump material from recycling bins to
landfill.
- lack of an adequate system of quantities,
sizes and locations of recycling bins.
- land is scarce and expensive so it is
difficult to locate recycling industries although the sector is good at
collecting higher value wastes e.g. metals, paper, second-hand electrical and
electronic products for reprocessing and reuse. Lower value materials such as
waste plastic, glass and food waste have little commercial interest. Little
space is available for landfill. Chemical waste treatment, sludge treatment
facility are almost completed. Plans are to build organic waste treatment
facility for food waste and to build energy from waste
facilities.
One model discussed in the HK plan is Taipei
City in Taiwan. In 1996 Hong Kong and Taipei had similar waste disposal per
capita per day - just over 1.2 kg. While the HK plan notes that waste is counted
in different ways: Taipei's is household garbage while Hong Kong is MSW in 2011
HK's waste production is still over 1.2 kg per person per day while Taipei's is
1.0 Kg (Taiwan as a whole is .4 kg and GallonLetter notes that Canada's
municipal waste is over 2.1 kg. per person per day).
Taipei's
Actions Which HK Identifies as Key to Success
After source separation and reduction,
remaining waste in Taipei City is treated in three incinerators and then
landfilled. The HK blueprint suggests that the way Taipei City reduced waste was
public education and volume-based MSW charging. When Hong Kong charged for
disposal of construction waste, waste loads to landfill fell by 60%
Charging for waste, both households and
commercial/industrial units combined with Producer Responsibility Scheme which
apply the Polluter Pays Principles, helped to develop recycling industries and
create green jobs in Taipei. Key legislative points include:
Taipei: 1997 4 in 1 resource
recovery
2000 volume based waste system
2002 Plastics restriction policies on
disposing cutlery and shopping bags
2004 Set up Food waste recovery
system
2005 Mandatory waste separation
2006 Mandatory food waste recover
In 2011 Taiwan had a recycling rate of 52%,
incineration 46% and landfill 2%
Producer Responsibility Schemes are planned as
part of the 10 year Hong Kong blueprint including:
- plastic shopping bags: extending existing
program and education for bring your own bag
- waste electrical and electronic equipment.
Public consultation complete; draft legislation
- glass beverage bottles
Other products to be reviewed over
time.
China: Ban on
Specified Waste Imports
Mainland China's ban on import of plastic
waste unless it met specific conditions e.g. sorted has put up what some call a
Green Wall about five months ago. Hong Kong recyclers (and many others from
around the world) have been used to sending plastic waste to China where while
some waste is recycled other waste is just dumped causing negative environmental
impacts. China's ban highlights that producer responsibility needs to ensure
that the product really is recycled.
Paid subscribers see link to
original documents and references
here.
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CALIFORNIA
BILL IN WAITING: EPR BY ANOTHER NAME
Just because the term EPR is not used in
legislation, doesn't mean that the effect isn't the same, according to Laurie
Hansen Sheets, executive director of the US-based Western Plastics Association.
She suggests that the California's Senate Bill 529, the Plastic and Marine
Pollution Reduction, Recycling and Composting Act is really EPR. The bill sets
high standards for curbside recycling, and prohibits fast food chains from using
disposable food service packaging or single use bags which are not either
recyclable or compostable. Statewide targets for packaging recycling or
composting set at 25% are to be achieved by 2016. Sheets said that the bill is
"EPR for everybody in the plastics industry" but with the emphasis on reducing
marine debris to protect coastlines which appeals to many Californians. The bill
"died" due to lack of a vote at committee but bills are active for two years and
can be revived.
Paid subscribers see link to
original documents and references
here.
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SERVICE
PROVIDER RESPONSIBILITY: SAFETY OF TRANSPORT OF HAZARDOUS GOODS ON CANADIAN
RAILWAYS
"What Transport Canada requires is
performance," said Pierre Poilievre, then Parliamentary Secretary to the federal
Transport Minister, recently promoted to Minister of State when asked on CBC's
The House about the impact of one person crews in relation to the oil-carrying
train cars and the deadly explosion in Lac-Megantic, "There must be a certain
performance of safety in the entire system and we show up and present as a
department 20,000 inspections in a given year to ensure that safety performance
is present. It's up to the railway to take responsibility for how it achieves
that level of performance. Some railways believe they can operate safely with
one operator, some railways use more than one. What's important to Transport
Canada is the safety outcome.
Right now we don't know if the problem in Lac
Megantic is in any way linked to the number of operators on board the trains. We
know one thing it wasn't a one man crew or a two man crew it was a zero man
crew. So it is possible that this has nothing to do with the number of
operators."
In general, GallonLetter supports the idea
that government should regulate performance rather than specify for companies
how to achieve this but there appear to be a few missing links in how the
federal government is dealing with transport of hazardous goods. Just saying
that safety performance is the responsibility of the railway is not government
regulation of performance. First of all, we could hardly believe we heard right
when Poilievre said that no crew on duty was somehow evidence that crew numbers
were irrelevant. We listened again and transcribed it to make sure we did hear
right. No wonder those Transport Canada safety inspections don't work if there
is no concept that performance regulation has to have some measures: e.g. in
lieu of fail-safe technology (something which seems to be rare indeed) some
people must be available and able to perform duties needed to ensure safety.
It's like operating an intensive care unit without any medical staff and then
saying, we'll just have to wait to determine why the patient died. Sure, the
patient might have died anyway but the chances for survival are much less if
there is no emergency response or skilled oversight during the greatest
vulnerability to crisis.
Thomas Mulcair, federal Opposition Leader,
took some early flack for criticizing the government for cutting corners on the
transport of hazardous products, cuts and deregulating which led to the
explosion in the small Quebec town. Some of the flack about Mulcair reaching his
conclusion too early was from the Conservative Party government which itself
doesn’t seem too worried about not having any evidence at all to support its
deregulation of the environment. Mulcair’s persistence and continuing insistence
may have led to Transport Canada taking some early steps in policy changes and
an opportunity for the NDP to present a motion to the Standing Committee on
Transport, Infrastructure and Communities convened on July 23, 2013 by the
request of four members of the committee.
2011 CESD
Report
Accidents and tragedies happen at times
despite best effort at prevention but the December 2011 report of the Scott
Vaughan, then Commissioner of the Environment and Sustainable Development in the
Office of the Auditor General of Canada, suggests serious problems in
transportation of hazardous goods in Canada, not only on rail but other modes
such as air, ship and pipeline. Among the headings for the observations and
recommendations were:
"Transport Canada
There is no national risk-based compliance
inspection plan
There is a lack of follow-up by Transport
Canada on identified deficiencies
Transport Canada does not know the extent to
which organizations transporting dangerous goods are complying with
regulations
Transport Canada does not conduct an adequate,
timely review when approving emergency response assistance plans
Management has not acted on long-standing
concerns regarding inspection and emergency plan review practices
National Energy Board
There is a lack of follow-up by the Board on
identified deficiencies
Oversight of emergency procedures manuals is
deficient
The Board has designed a sound risk-based
monitoring approach, but improvements are needed in its
implementation"
Chapter 1 of the 2011 audit report gives more
details.
The Commissioner wrote that "Environmental
stewardship is complex. It must be supported by scientific knowledge,
environmental monitoring and effective enforcement." He said his report "cites a
lack of diligence by Environment Canada, Transport Canada and the National
Energy Board in verifying that regulated parties have corrected identified
instances of non-compliance." GallonLetter notes that without enforcement, there
will always be companies which will make money by cutting corners; without
enforcement, "performance regulation" becomes an excuse for lack of proper
management by government causing harm to innocent bystanders and the
environment, as an unintentional (we hope) but inevitable result of the pursuit
of "economic action." at all costs.
Recent press coverage in relation to the train
explosion show Transport Canada may have made less progress than they committed
to in response to the audit report.
Paid subscribers see link to
original documents and references
here.
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ECO CANADA:
ENVIRONMENTAL INTERNSHIPS AND WAGE SUBSIDIES
Eco Canada administers two programs funding
internship programs in environmental roles:
- National Environmental Youth Corps: 33% wage
subsidy to a maximum of $8,000 for companies hiring recent graduates and
providing training and experience. Funding is from Human Resources and Skills
Development Canada.
- International Environmental Youth Corps: 33%
wage subsidy to a maximum of $12,000 also for companies hiring recent
graduates and providing trains and experience that includes international
exposure e.g. liaison with foreign companies or working abroad, attending a
conference outside Canada. Funding is from Environment Canada.
Such funding may be available in cycles but it
is something for both new grads and companies to be aware of. Earlier in the
season, we were asked for some advice, directed the grad to ECO Canada and the
funding was approved quite quickly and the recent grad was soon working in an
environmental field. ECO Canada also maintains an environmental jobs
board.
Paid subscribers see link to
original documents and references
here.
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NEW CROPS FROM
WILD RELATIVES
Wild relatives of crop plants are seen as an
important source for developing new crop varieties to adapt to global
environment changes, according to a new report by PwC (see GallonDaily). Some
see perennial crops as moving towards sustainability because they protect soil
and habitat because they hold the soil and need less tillage. New fruit crops
are showing up locally as well.
GallonLetter has met several local tree
seedling growers of Pawpaw, a small, tropical-looking tree with the largest
edible fruit of any native tree which used to be common in southwestern Ontario
and is grown in eastern North America; the local tree growers have waiting lists
for seedlings. Ernest Grimo of Niagara-on-the-Lake who ought to receive an Order
of Ontario at least for his lifelong work on developing nut crops as well as
other rare tree fruit sells pawpaws to specialty restaurants but only on
condition that the "genetic material" ie the seed is returned to the Grimo farm.
Purple-blue Saskatoon berries were used by
native peoples to make pemmican and for many people on the prairies were
traditional foraged-from-the-wild ingredients for pies and jams and now are sold
at our local farm markets. GallonLetter's editor found it amusing when we were
in Niagara Falls where the landscaping included saskatoon berry trees; there
were signs all over advising tourists "Please do not feed the Raccoons" - the
only trouble was that the raccoons were feeding themselves: the dozen of trees
were loaded with luscious fat berries and with fat raccoons who shook the small
trees as they scrambled all over to eat the berries.
One fruit we weren't able to find to try is
the edible blue honeysuckle so we were delighted to find it for sale at a local
farm market; once we expressed some knowledge about haskap the grower who was
very pleased about the success of her new crop told us all about it: how long it
takes for the shrub to produce, the eagerness of birds to eat them, their
delicacy, the wonderful taste, the plans for the future to grow different
varieties.
Haskap from
Blue Berry Honeysuckle
A type of edible blue berry honeysuckle, the
name of Haskap is said to apply to only seven varieties most of which have been
bred and selected at the University of Saskatchewan field trials. At Haskap Day
held July 19, 2013, attendees could see, taste berries and find out how haskaps
are grown, how selections have been made from native Canadian, Japanese and
Russian varieties and harvested. Dr. Bob Bors, one of the key presenters, also
wrote a paper about the challenges of propagating from wild stock which tend to
be too variable for commercial production: "The good varieties taste something
like blueberries and raspberries. The bad ones taste like tonic water!" The
variations of the wild stock may make the berries unsuitable for commercial
production. In the wild, the berries can be pointed which makes them too
vulnerable to damage, too small, lumpy and too sparse. Getting the taste, the
right shape and larger size, enough firmness for mechanical harvesting without
sacrificing tenderness requires thousands of seedlings to be grown and
evaluated. And then certain varieties only set fruit if there is another variety
of haskap which blooms at the same time.
By buying these less-well-known crops
especially those produced locally, eaters can help develop the local
farm-to-consumer economy, the possible environmental benefits of protecting wild
genes and the habitat of wild species which could provide similar benefits over
the long term.
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READING
GALLONDAILY
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Recent topics include:
- UK government invests in low carbon
automotive technology
- 3D printers may pose indoor air pollution
risk
- Cashmere sweaters may be harming snow
leopards and other endangered species
- Wild relatives of food crops have a potential
value of $196 billion
- More research on silver nanoparticles
- Subway versus LRT debate ignores real issues
- Dissolvable is not a solution to garbage
- Research on public attitudes towards serious
risks
- Mercury in product rules to be ratified in
October
- Environment: new threats emerging
- Environmental group claims environmental
consultant has undisclosed conflict of interest
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