Next Year the Waste (Scotland) Regulations come into play stipulating all businesses must separate out materials for recycling. Andrea Lockerbie finds out how the country has been gearing up for change
Billed as a real step change in the way resources are managed in Scotland, particularly for organic waste, the Waste (Scotland) Regulations make it a legal duty for all businesses, regardless of size, to separate metal, plastic, paper, card and glass for recycling from January 1, 2014. There is also a ban on these separated materials being sent to landfill or incinerators, and those producing more than 50kg of food waste a week in urban areas must separate it for recycling.
This has required both businesses and waste management companies to change the way they manage and handle their recycling and waste.
Regional waste management firm William Tracey has viewed the regulations as a “real opportunity” to develop new services. It took a proactive approach to the new regulations coming in, producing an information booklet for clients, running seminars and running a monthly advertising campaign in The Herald and The Scotsman.
Robin Stevenson, William Tracey’s managing director for its non-hazardous division explains that to prepare its clients for the change it did a ‘brown paper exercise’, charting how to convert its customers from their existing waste and recycling service to one compliant with the new regulations.
It has also conducted internal training for all drivers and staff. As drivers are the main regular contact for customers, their knowledge of the new regulations is critical: they have been the ones answering customer questions, and will ultimately have the power to not collect non-compliant bins.
Load inspectors at each of Tracey’s depots are also tasked with ensuring that what is on the duty of care document and tip ticket is what it says it is, as extra quality control.
Tracey’s has also invested in three-pod vehicles to collect dry mixed recyclate (DMR), food and glass separately on the same collection – offering cost, logistical and carbon footprint benefits. One of these vehicles has been operating “extremely well” in Edinburgh and four more have been ordered, for use in Glasgow and Edinburgh.
Inspired by the split-bodies vehicles, it also worked with bin manufacturer Taylor to develop a split bodied metal container, with two lockable lids – allowing businesses to collect two materials within the footprint of one container, and for these materials to be tipped into vehicles separately.
“The infrastructure we have had to invest in is key,” Stevenson says. It has also changed all its depot licenses to take food waste, to be bulked and sent to its Barkip AD facility.
Handling and treating food waste and separate trade glass collections are brand new for Tracey’s – a direct result of the new regulations.
The regulations stipulate that materials can only be commingled where the quality of material is not reduced. Because of this, Tracey’s will collect glass separately from other recyclables, as no facility in Scotland can cope with glass in DMR. Tracey’s adds that it would struggle to sell commingled material, if off-takers knew it had been collected with glass.
What are Stevenson’s views on whether to collect paper, metals and plastics together or separately?
“It is almost impossible to have every separate collection service. If you take some of the city centre businesses they will struggle to have a couple of small containers. So another thing we have had to do is look at our collection frequencies. At the moment we are re-routing our trucks in Edinburgh, for example. We now have a truck in Edinburgh that goes into the city centre three times in 24 hours. You can imagine the impact of that if you didn’t have a split bodied vehicle. So we have had to look at the logistics as well as how we collect that material.”
Some have questioned whether the regulations will drive more material out of the general waste to the detriment of quality. Sean Keenan, William Tracey’s head of alternative fuels and resource trading says management and ensuring customers do not put “anything” in DMR collections will address this. “We’ve made mixed recyclate bins that give a lot of detail about what can and cannot go in. My only fear is that other companies might be lazy and say you don’t need a general waste bin at all anymore.”
Stevenson believes there will be an initial dip in quality of material collected: “I think the quality of dry mixed recyclate and mixed paper in particular is going to go downhill a little bit before it gets better. At the moment you have got people who want to recycle, therefore they are willingly doing it and separating it out. Come 1 January you are going to put a basket of people in there who are forced to do it. This is why I say it is our drivers that need to be fully engaged with this legislation, because ultimately it is going to be our drivers who decide whether to collect that container-full of material or not.”
To counter this, it will have extra pickers on, to ensure that output from its MRF remains the same quality.
Tracey’s has invested time and money into preparing for the new regulations, so wants to see them strongly policed by SEPA. “My view is you either wear a seatbelt or you don’t wear a seatbelt – you either conform to the legislation or you don’t conform to it,” says Stevenson. “If they have a softly, softly approach you will find that the people who have not invested in the infrastructure and to meet the new regulations will start to flount the law and that is where you will get your quality issues.”
Adrian Bond, National Waste Manager for SEPA confirms that early focus will be “on advice and support” but insists that “high impact, persistent offenders will be tackled more robustly”.
He adds: “SEPA has been working closely with each of Scotland’s 32 local authorities to develop a nationally consistent approach to enforcement. Ongoing engagement with environmental health teams, trade waste inspectors and waste managers has been invaluable in developing targeted compliance campaigns.”
Bond says large food waste producers will be a key target area and the agency will also focus efforts “on waste collectors who persist in offering single mixed collection services with no segregation of recyclables”.
Contrary to the notion that the new regulations will save businesses money, Stevenson believes they will initially see a slight rise in their waste management costs, with savings achieved over the long term as landfill tax rises. “The only difference the customer will see is more bins on site and it will be a different vehicle collecting. The customer will see very little change, apart from a slight increase in cost.”
Zero Waste Scotland has been involved in awareness raising, working with the waste sector, providing funding support for new systems needed and working with businesses themselves.
Iain Gulland, director, Zero Waste Scotland:
“This is really going to significantly change business recycling in terms of obligating companies to recycle more – and food waste – which is the big change. Companies who deal in food are going to have to separate that out for collection and that is going to have huge impact in terms of getting food waste out of businesses.
I think we are all geared up for it in Scotland now and businesses are well aware of the new regulations coming through.
The waste industry can see there is a huge business opportunity for many of them. It has also allowed them to re-engage them with their customer base, from being, with respect, a back-door operation, to going in the front door: into boardrooms, at management level of businesses and engage with them. That has opened up opportunities for different recycling services and to secure new businesses.”