With the Scottish zero waste regulations having been in place for more than a year it feels like a good time to have a look at how successful the implementation has been and their impact on recycling in Scotland.
As I started writing this piece it also caused me to consider the issue of regulation in a broader context: do we have the right amount and is it effective in achieving the desired objective?
Communicating Scotland’s zero waste regulations, and watching with interest the introduction of what some might see as a slightly watered down version in England a year later, took me back to the pre-treatment regulations in England in 2007 (something like this already existed in Scotland). There are some striking similarities.
The pre-treatment regulations require waste to be treated by a physical, thermal, chemical or biological process, which includes sorting. This, in effect, means that a proportion of each waste stream must be separated out for recycling. While the responsibility for pre-treatment lies with the producer – and they are perhaps slightly less prescriptive – one wonders if the desired objective is all that different from the more recent regulation?
To complete the customer, collector, processor chain, the Scottish Government is introducing a MRF sampling protocol. This requires recycling companies to sample materials and supply composite analysis data to the Scottish Environment Protection Agency on a quarterly basis. For many businesses, including ourselves, this will require further investment and additional staff to ensure full compliance.
All too often I feel we over-emphasise the importance of regulation. It can only ever be a contributory factor, and advances made as a result of social and commercial drivers will consistently outperform it. Customers’ environmental and sustainability objectives will more often than not dwarf the ambition of policy.
Business has realised that effective reuse and recycling makes sound financial and commercial sense, and it is continually pushing the industry to find new ways to optimise its service such as our new pod vehicles, which collect dry mixed recyclate, food and glass separately on the same vehicle. Indeed, the more pioneering of these companies are now looking at direct ways to build materials back into more sustainable supply chains, helping them develop circular business models.
So in terms of the volume of recyclate, the impact of the zero waste regulations on Scottish recycling has been quite significant, and we are now seeing an increase of around 25% in the amount of material arriving at our recycling facility in Linwood, Glasgow.
But, as ever, it is not all good news. This growth in volume has been coupled with an increase of more than 12% in contamination levels of what we receive. So we now have to spend considerably more on the processing of this material to get it to an acceptable standard for the reprocessors.
It is now vital that the industry, supported by Zero Waste Scotland, works to increase the awareness of quality. The drop in the threshold for separate collection of food waste from 50kg to 5kg per week from 1 January 2016 provides us with the ideal platform for this communication. Failure to do so could present the situation where food waste simply becomes the new general waste, increasing the likelihood of rejection from anaerobic digestion facilities, which already have limited capacity.
Overall, I believe we probably have about the right balance of regulation. We must be mindful that the common denominator of all regulation is that it increases costs and a proportion of these costs are ultimately passed back to the waste producer. We must therefore ensure that we regulate only where other market forces are failing and there is a likely risk to health or the environment.
Developing and implementing new policy and regulation is one thing. But to ensure that it is effective and supports us in meeting our objectives, we must also ensure that it is appropriately enforced. Companies such as the William Tracey Group have made significant investments to ensure compliance for customers and themselves, and the lack of consistent and proportional enforcement, to ensure a level playing field, will make further investment more challenging.
I have always been a strong supporter of the Scottish Government’s Zero Waste Plan, its vision for a zero waste society and its willingness to use regulation as a tool to support these aims. I am proud of what Scotland has achieved in improving its resource efficiency, and I am also confident that, as long as the sector commits to increasing awareness, we will address the issue of quality.
Robin Stevenson is managing director of non hazardous waste at William Tracey Group