Bip 2102-2006

E N V I R O N M E N TA L M A N A G E M E N T R E P O R T
Focus on Waste Management

Mark Yoxon, Stephen Burnley and Toni Gladding
ENVI RON MENTAL MANAGEMENT REPORT
Trends and Best Practice in
Waste Management
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ENVIRON MENTAL
MANAGEMENT REPORT
Trends and Best Practice in
Waste Management
Mark Yoxon, Stephen Burnley

and Toni Gladding
First published in the UK in 2006 1
by
BSI 2
389 Chiswick High Road
3
London W4 4AL
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in association with
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The Open University Press
Walton Hall 6
Milton Keynes MK7 6AA
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© The Open University 2006 8
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All rights reserved. Except as permitted under the Copyright, Designs and Patents Act 1988, no
part of this publication may be reproduced, stored in a retrieval system or transmitted in any 10
form or by any means – electronic, photocopying, recording or otherwise – without prior
permission in writing from the publisher. 1
2
Whilst every care has been taken in developing and compiling this publication, BSI accepts no
liability for any loss or damage caused, arising directly or indirectly in connection with reliance 3
on its contents except to the extent that such liability may not be excluded in law.
4
The right of Mark Yoxon, Stephen Burnley and Toni Gladding to be identified as the authors of 5
this Work has been asserted by them in accordance with sections 77 and 78 of the Copyright, 6
Designs and Patents Act 1988.
7
British Library Cataloguing in Publication Data 8
A catalogue record for this report is available from the British Library
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BIP 21 02
20
ISBN 0-580-4841 2-2 1
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Typeset in Akzidenz Grotesk and Minion by 4

Florence Production Ltd, Stoodleigh, Devon
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Printed in Great Britain by
MPG Books, Bodmin, Cornwall 61
Contents
1 Introduction to the report 1
Chapter summary 1
Some examples of cost savings 2
Some examples of fines and prosecutions 3
Benefits of waste management 5
2 What is waste? 7
Chapter summary 7
Waste in general 7
Identifying waste in the workplace 9
Waste terminology 11
How much waste do we produce? 13
3 Why bother with waste? 17
Chapter summary 17
Introduction 18
Keeping on the right side of the law 20
The financial drive 22
Commercial pressures 25
Environmental aspects 27
What should I do with my waste? 29
4 How to manage waste 31
Chapter summary 31
What is effective waste management? 32
A waste review – the seven steps to effective waste management 34
5 An introduction to key waste legislation 49
Chapter summary 49
Background – who are the regulators? 49
European directives 50
Waste strategies 53
CO N TE N TS
The Landfill Directive 56 1
The Environmental Protection Act and Duty of Care 57 2
Packaging waste 60 3
Hazardous waste 61 4
WEEE Directive 63 5
End-of-life vehicles 65 6
6 Waste management in relation to other management systems 67 8
Chapter summary 67 9
Introduction 68 10
Why integrate waste management with other management systems? 68 1
Integration 69 2
Integration in practice 73 3
7 Waste terminology 83 5
8 Gateways to help and support 89 7
Legal issues 89 8
General enquiries 90 9
Technical enquiries 90 20
Other useful contacts 91 1
Appendices 3
1 Checklists for waste review 93 4
2 History of waste and recycling 1 01 5
3 Outline of legislative drivers for waste management and likely 6
future impacts on business 1 09 7
4 Case study solutions for Chapter 6 1 21 8
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An executive summary
Waste costs your business money. On average this adds up to 4.5% of turnover or approx-
imately £650 per employee per year. Most businesses significantly underestimate waste
costs, often by a factor of 1 0. You pay for raw materials, and any that don’t end up in the
product or service you provide become waste, attracting further costs for storage, treat-
ment and disposal. Disposal costs are rising year on year. Savings and payback are mea-
sured in months, not years. Effective waste management will improve competitiveness and
the bottom line. Consider your turnover to profit ratio. If you could save even the average
4.5% by minimizing or eliminating waste could you match this figure by increasing sales?
Alongside the potential cost savings sit several other drivers for addressing waste man-
agement.
• Legislation ratchets up year on year; keeping ahead of the game makes business sense
and adds up to measurable benefit.
• A whole raft of stakeholders, from banks and insurance companies to non-govern-
mental organizations, shareholders and the public, expect and increasingly demand
that business improves its environmental performance. Alongside energy manage-
ment, waste management is one of the easiest and most beneficial ways of addressing
these issues.
Effective waste management is straightforward, and can often be achieved with simple
changes to operational procedures. It is a surprise that so often it is a missed opportu-
nity. The purpose of this report is to provide the tools and techniques to unlock the
benefits of effective waste management.
Chapter 1 sets out the background and gives examples to show that waste management
equals business benefit.
Chapter 2 answers the question ‘What is waste?’ and unmasks the hidden activities that
contribute to lost profits.
Chapter 3 expands the business case for waste management and includes details of the
reasons for addressing waste issues, i.e. the legal, fiscal and market advantages.
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AN EXECU TI VE S U M M ARY
Chapter 4 provides the ‘How to’ details of a waste review to take stock of what is actually 1
happening and to develop organizational intelligence on what causes waste, where it is 2
being generated and how to make informed management decisions to develop a waste 3
management strategy. 4
5
Chapter 5 expands the introduction to waste legislation in Chapter 3 and sets the scene
6
for existing and future legislative drives for waste management.
7
8
Chapter 6 provides guidelines for integrating waste management activities with existing
9
or planned management systems such as quality and health and safety. It makes the busi-
10
ness case for integration rather than replication of effort.
1
2
Chapter 7 sets out some of the main terms associated with waste and waste manage-
3
ment.
4
Chapter 8 is intended to provide authoritative sources of help and advice. 5
6
Finally, a series of appendices provide information to supplement the main body of the
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report.
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I n trod u cti on
1
Su m m a ry
There is an inescapable fact about waste: it costs you money. From Government
figures, we estimate that could add up to £650 per employee per year. Do the maths
for your organization – it adds up to real and uncontrolled loss of profit. Trends
and Best Practice in Waste Management helps you make sense of waste management
as a business issue, and manage waste and in turn your resources more effectively.
By doing so you will save money, develop good business practices and greater process
efficiency. We include practical solutions, tools and techniques to demonstrate and
help you establish effective waste management in your organization, and save more
than the environment.
This report sets out to answer some fundamental questions about waste and waste
management. The answers add up to an effective waste management strategy for
your business.
Key q u esti on s An swers – Ch a pters:
Wh at is wast e ? 2 & 7
H ow m u ch is was te co st i n g th e b u s i n e ss ? 3, 5 & Al l
Wh at are th e b e n e fi ts o f e ffe cti ve wast e m an ag e m e n t ? 3 & 2
H ow do I st art to m ake s e n se of was t e m an ag e m e n t ? 3 & 5
H ow can I d e ve l o p a wast e m an ag e m e n t s trat e g y? 5
H ow do I m ake se n se o f was t e l e g i s l ati o n ? 6, 4 & 8
Wh y an d h ow do I i n t e g rat e wast e m an ag e m e n t wi t h 4 & 5
o th e r m an ag e m e n t sys t e m s ?
Wh at can I l e arn fro m o t h e rs ? 8 & Al l
Wh e re can I find h el p an d ad vi ce ? 8
Wh at d oes th e j arg o n m e an ? 7
Trends and Best Practice in Waste Management has been written to help you make sense
of waste as a business issue. There are many reasons why an organization needs to focus
attention on waste management. The bottom line is that it costs money. On average,
your business is likely to be spending 4.5% of total turnover producing waste. This waste
needs to be stored and disposed of, further increasing costs. The true cost of waste –
materials, energy, labour and treatment – is usually at least five and can be up to 20
times the cost of disposal. What does this add up to for your business?
1
TRE N D S AN D B EST PRACTI CE I N WASTE M AN AG E M E N T
There are fundamental business reasons, as well as environmental ones, for minimizing 1
waste. 2
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• A systematic waste minimization programme could save 1 % of turnover.
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• Every pound saved on material costs goes straight to the bottom line and the average
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payback periods for such initiatives are measured in months, not years.
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• Savings of around £1 ,000 per employee are typically made through resource efficiency
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programmes.
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• Many waste minimization measures cost virtually nothing, are simple to implement
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and yield significant results.
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• Customers increasingly favour companies who have good environmental credentials.
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• More and more businesses demand resource efficiency from their suppliers and part-
2
ners.
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• Legislation, both in the UK and from Europe, is forcing us all to address the issue of
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waste. Non-compliance means fines and, in the worst case, custodial sentence.
5
6
Examples of cost savings 7
Abbott Laboratories manufactures pharmaceutical and healthcare products. Low- or no-
from Envirowise
cost waste management initiatives, for example waste water and solid waste, have 8
saved it over £1 75,000 per year.
9
Pfizer Ltd replaced expensive fibreboard packaging with cardboard boxes, saving
£70,000 per year with a 30% saving in freight cost to the customer. 20
GEC Marconi Avionics set up a waste minimization scheme in its metal finishing facility. 1
Implementing just one idea – using a new type of spray gun – from its weekly 2
brainstorming session turned an investment of £1 ,000 into a saving of £8,000 per year.
3
Abbott Laboratories saved £30,000 per year by ensuring that pump water seal flushes
used water only when the pump was required. 4
Kimberly-Clark reduced water use, saving £93,000 on water costs and a further 5
£34,000 on solid waste disposal costs. 6
Whatman International Ltd replaced shrink wrap with wide tape material and saved 7
£1 2,000 per year.
8
A Scottish rural high street community of small retailers worked together and saved
£9,750 per year through water savings and reducing waste and so reduced disposal 9
costs. 30
A contract packaging company investigated all aspects of its packaging and saved 1
45% on waste removal costs by segregating waste and reducing volumes in the general
waste skip. 2
Lowering the sides of cardboard transit trays saved a pet food company £1 00,000 per 3
year. 4
Reducing the thickness of shrink wrap film by 22% saved a major healthcare retailer 24 5
tonnes of materials and £27,000 per year.
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1 . I N TRO D U CTI O N
Investigation of packaging options and reduced waste packaging by The Boots Group
reduced PVC use by 30 tonnes per year, reduced environmental impacts and saved
£21 4,000 per year.
By working closely with major customers and suppliers, CCl Custom Manufacturing
eliminated 1 4 tonnes of plastic trays, improved packaging efficiency and saved
£263,000 per year.
Crown Copyright Envirowise (2006)
Examples of fines and

Three family members and a waste contractor were given fines totalling over £1 2,000 prosecutions from the
and a 1 80-hour Community Service Order at Newport Crown Court in March 2005 Environment Agency
following persistent illegal waste activities at a site in south Wales.
A multi-agency crackdown on environmental crime in west, east and south Yorkshire
and north east Derbyshire landed at least four people in the cells for allegedly
committing waste offences, and around 1 50 vehicles were checked as part of stop
and search operations.
A Somerset cheese company was ordered to pay £1 3,1 26 in fines and costs for
failing to recycle waste packaging. The Environment Agency visited the company in
August 2003 and found the packaging weight registered was vastly underestimated.
Instead of around 50 tonnes, it turned out to be 426 tonnes.
A west country garage business was ordered to pay a total of £1 1 ,000 in fines and
costs for waste offences after hundreds of tyres and flammable chemicals were
dumped in the countryside.
A firm that supplies chicken and other products to 1 0% of all Indian restaurants
across the UK was ordered to pay £5,326 in fines and costs for contravening
regulations on recycling of packaging waste.
A Stoke-on-Trent man was sentenced to four months’ immediate imprisonment after
repeatedly tipping building and excavation waste illegally on green belt land. After a
three-day trial and being found guilty of five offences, the man was also ordered to pay
£9,574 in costs to the Environment Agency.
Crown Copyright Environment Agency (2006)
The key point about prosecution is that its impact goes far beyond fines and inconve-
nience. These are in the public domain and are picked up by the media. Bad press and
bad business practice ultimately lead to loss of credibility and loss of business.
So the focus for effective waste management is a combination of bottom line and the
potentially negative impacts of non- compliance with legislation. We discuss these issues
in more detail in the report.
3
All forward-looking organizations have resource management firmly on the business 1
agenda and ask questions such as: 2
3
• how can I make more from less?
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• how can I maximize my business efficiency?
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• how can I maintain legal compliance with changing waste and related health & safety
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legislation?
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An important part of this internal debate centres on the effective management of waste
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in the business and discovering how and why waste is created in the first place.
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1
This report helps you examine waste as part of effective resource management throughout
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the business cycle. It moves beyond simply looking at waste as an inevitable outcome of
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business activity and helps focus on a wider consideration of waste management by
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asking questions and suggesting ways you can find your own answers to:
5
• how do you procure materials and services? 6
• how do you use raw materials in the business? 7
• how do you utilize transport and distribution in the business? 8
• how do you develop your staff competencies so they can carry out their jobs effectively? 9
20
For a waste management plan or strategy to take root in the business, it needs top-level
1
support. This begins with the board, who will need a clear set of arguments and ideally
2
irrefutable evidence that any plan for waste management is:
3
4
• necessary – citing legislation, competition, costs of waste disposal, market pressures;
5
• affordable – with clear, accurate costs on the table. Look for some quick wins. Calculate
6
payback periods;
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• cost-effective – with accurate projections of savings;
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• going to improve profitability – with demonstrable examples. Talk about others who
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have done it. The contacts in Chapter 8 provide examples from different business
30
sectors.
1
• likely to attract more customers and business partners – talk with suppliers, customers
2
and potential partners, and give examples of feedback and good practice.
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1 . I N TRO D U CTI O N
Further examples of
A Leicestershire dyer estimated effluent disposal costs at £50,000 per year. The true business benefits from
cost was £1 50,000 per year. A waste minimization programme reduced effluent costs Envirowise
by 1 9% or £28,500 per year.
Setting one scouring machine correctly to minimize water use saved 1 20 litres of
water per minute or £1 5,000 per year in metered water costs.
Regular water use and monitoring by J W Lees & Co (Brewers) Ltd reduced annual
water consumption by 40% and saved £1 00,000 per year in water and beer costs.
Mass balance techniques and systematic key environmental performance indicators
helped Robinson Brothers Ltd, a manufacturer of organic chemicals, reduce raw
material entering the waste stream by 36 tonnes and generate cost savings of
£1 85,000 over a two-year period.
Introduction of paint monitoring equipment to reduce the quantities of waste paint left
over after respraying work saved a small accident repair shop £1 2,000 per year and
reduced paint and solvent consumption by 20%.
Waste analysis at Fenner Dunlop, a multinational manufacturer of conveyer belts,
reduced belt cut-off waste to less than 1 %, saving the company £220,000 with no
capital investment.
A waste review at SCA Packaging resulted in a reduction of 520 tonnes of process
waste and 1 5% reduction of adhesive use. Cost savings amounted to over
£1 00,000.
A U K specialist chemicals company carried out a waste review and reduced water use
by £300,000 per year and saved £400,000 on raw materials. The chemical oxygen
demand of effluent was reduced by 50% with further treatment cost reductions.
A small vehicle engineering company reduced general waste by 82% and costs by
£3,962 per year through simple environmental performance monitoring.
Severn Trent Laboratories Ltd eliminated a solvent washing procedure, saving £7,000
per year through solvent purchasing and disposal costs. Other benefits included lower
levels of employee exposure to organic solvents and lower volumes of hazardous
waste requiring disposal. A waste minimization culture has been firmly established.
Replacing conventional cardboard packaging with reusable plastic containers has
helped a pharmaceutical company save £39,000 per year after investment costs.
Supplying braking system components for the automotive industry has helped
Continental Teves Ltd save over £81 ,000 per year and reduce waste. Continental
Teves has actively and successfully encouraged its suppliers to adopt similar practices
and switch to reusable packaging.
Crown Copyright Envirowise (2006)
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What is waste? 2
Summary
Waste can be defined as anything that the business wants or needs to dispose of,
whether the material ends up in a landfill site or as feedstock for the recycling
industry.
In its widest sense, waste can be a solid, liquid, gas or even an energy stream (such
as warm water going down a drain) . If we are trying to reduce the waste generated,
it is important to adopt this wide definition because there are often links between
the waste of one type of resource and the waste from another (materials and energy
for example) .
Organizations can ‘hide’ waste under a multitude of euphemisms, but we need to
be honest and recognize waste in all its forms.
Several different types of solid waste are recognized by the regulators, ranging from
inert waste to hazardous waste. Any class of waste can comprise many different
materials, and it is important to identify which types of waste are produced in your
organization.
2.1 Waste in general

‘What is waste?’ This is a very good question. There are many different types of waste
and just about everything your organization does produces some kind of waste. To help
set the scene in your own mind, have a go at the following activity.
Activity
Spend 5–1 0 minutes thinking about what ‘waste’ means to your business and write down
a few of your thoughts.
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
7
Your answers will be influenced by the size of your business, the activities that your busi- 1
ness carries out and your role in the organization. 2
3
If we did a survey among the general public, we would come up with another set of lists
4
that reflected the particular individual’s thoughts, ideas and values. For example, a keen
5
gardener would regard a pile of vegetable and fruit peelings as a valuable contribution
6
to the compost heap, while another person would regard the same material as unpleasant
7
waste.
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But can we come up with a definition of waste? Two children came up with the following
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suggestions:
1
2
“Rubbish and stuff that people don’t want.” (Christopher aged 8)
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“What we produce and throw away; things we don’t need.” (Andrew aged 1 1 ) 4
5
Two perfectly reasonable definitions, but we could also look at the European Framework
6
Directive on Waste for a more official view. According to this directive, waste is defined
7
as:
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‘Any substance or object which the holder disposes of or is required to dispose of in pursuant
20
to the provisions of national law in force.’
1
2
Both the children and the directive have focused on the fact that waste is something that
3
we want (or need) to get rid of. Equally, the definition leaves the question of our fruit
4
peelings open; they may or may not be a waste. Both these definitions focus on an
5
assumption that waste production is something that happens. Our focus in this report
6
is to challenge and quantify this assumption, and by doing so add value to the business.
7
Note that material that you or your business segregates for recycling is still a waste or 9
‘something you don’t want’. Taking office paper as an example, it is certainly better to 30
send this material for recycling than for disposal to a landfill, but (as we will investigate
in Chapter 3) it would be better still if the waste was not generated in the first place. 1
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2 . WH AT I S WASTE?
2 .2 I d en ti fyi n g waste i n th e workpl ace
Waste is everywhere in the workplace. A good starting point is to look at everything that
enters and leaves the workplace. Consider the firm shown in Table 1 . Models such as
this, which are based on inputs and outputs, are a useful way of identifying waste. These
models can be developed into what are known as ‘mass balances’. A mass balance quan-
tifies the weight of every material entering each input stream, the weight of material (by
type) in each output stream and the weight of any materials accumulating in the system.
This can then be used to help identify the areas we need to concentrate on if we are
trying to reduce the amount of waste we produce. You may wish to produce a mass
balance for your business premises once you’ve worked through Chapter 5.
You may be surprised to see some of the ‘wastes’ included in Table 1 . Indeed, the EU
directive’s use of the word ‘substance’ would suggest that the energy losses are not wastes.
However, any energy manager or financial controller would certainly see a hot radiator
immediately below an open window as a ‘waste’.
Table 1: Workplace inputs

I n pu ts O u tpu ts
and outputs
Fuels and energy Energy
Electricity Space heating losses
Gas Process heating losses
Oils Boiler emissions
Solid fuels Noise
Solids Solids
Equipment and machinery Process wastes
Raw materials Office waste
Finished products Kitchen waste
Office materials Packaging
Food Grass cuttings
Equipment and machinery
Construction, demolition and
redecoration waste
Repair and maintenance wastes
Liquids Liquids
Water Sewage
Raw materials Process liquids
Solvents Run-off
Vehicle washing
Gases
Boiler emissions
Process emissions
On-site vehicles
9
The emphasis of this report is on solid waste, so the following chapters are not directly 1
concerned with waste energy, liquids and gases. But it is essential for all staff concerned 2
with waste to appreciate that, when it comes to any business activity, resource consump- 3
tion and waste are inextricably linked. For example, an energy-inefficient heat-based 4
process may also be generating excess solid waste through the need to reject sub-standard 5
material that has not been treated sufficiently. So, as you will see in Chapter 5, savings 6
identified in one area will often lead to savings in a different area. 7
8
But, when it comes to waste, beware. Waste can be hidden by using a variety of less
9
unpleasant terms. Take a look at the list in Table 2 – these are all terms that really mean
10
‘waste’. How many of them are used in your workplace?
1
2
Table 2: Terms for waste
scrap packaging sludge 3
rejects tank loss rubbish 4
returns cleaning loss refuse
losses excess stock garbage 5
material variances contamination trash 6
broken damage downgraded
tails moisture content credits 7
end of run cleavage loss dust 8
set up loss over-make core loss
residue swarf slab off 9
allowance non-standard deckle loss 20
overfill yield loss consumables
stock loss make ups evaporation 1
stock adjustments give away samples 2
side runs hidden loss trials
trim extraction washings 3
salvage batch growth over issue 4
unavoidable losses cross-contamination factory shop
geometric losses dipstick error sweepings 5
rework over-specification dross 6
DMCS unauthorized use shortages
under-delivery shrinkage seconds 7
obsolete stock standards overweight 8
industry standard leakage defects
spillage cancelled order process loss 9
30
1
Activity 2
3
Find out how many of these terms are used in your workplace.
4
Do you have any descriptions for waste in your business that are not included in this list? 5
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2.3 Waste terminology

Like all subjects, waste management has its own jargon and attaches highly specific mean-
ings to some everyday terms. To help you through this, we have put together a summary
of some of the more important terms used to describe waste. You will meet several of
these terms in this report, and in your dealing with waste at work.
Inert waste This waste consists of substances that are physically and chemically unre-
active; when disposed of they don’t dissolve and contaminate water supplies, or
decompose giving off harmful gases. Ceramics, rocks, clean soil and some types of
ash are all examples of inert waste. These materials attract a much lower rate of land-
fill tax [£2 per tonne against £1 8 per tonne (in 2005) for active waste] , but they still
take up landfill space and deplete the nation’s landfill capacity.
Household waste This is the waste we produce at home. However, it consists of more
than ‘dustbin waste’. Waste taken to public waste sites and waste put out for recycling
or taken to a recycling bank is also classed as ‘household waste’.
Municipal solid waste This consists of household waste plus waste produced by busi-
nesses that is similar in composition to household waste and is collected as part of
the local authority collection system.
Note that some European and national waste recycling and recovery targets refer to
‘household waste’ and some refer to ‘municipal waste’. So the difference between the
two terms (which represents business waste) can be important. This situation also
means that the way your waste is regulated can be dependent on which system collects
the waste (the local authority service or a private arrangement between the firm and
a waste management company) .
Hazardous waste Until 2005, hazardous waste was known as ‘Special Waste’ in the UK.
It is the waste with the greatest potential for causing harm to the environment or
public health. Typical hazardous wastes contain toxic substances, flammable liquids,
asbestos, strong acids and alkalis. But waste fridges and freezers are also classed as
hazardous waste due to the presence of substances that could damage the ozone layer
in older appliances. 1
1 At the time of writing (spring 2006) the Hazardous Waste Regulations (2005) are not fully implemented in
Scotland and Northern Ireland.
11
Clinical waste Waste generated by healthcare activities (such as GPs, hospitals, vets, 1
laboratories) . Clinical waste covers everything from used sticking plasters through 2
waste medicines to human organs and other operating theatre waste. If your firm has 3
a first aid room you may be producing clinical waste – which is best managed through 4
the services of a specialist contractor. 5
6
Industrial waste This is the waste produced by manufacturing industry. It could consist
7
of everything from inert waste through to hazardous waste.
8
Commercial waste This is the waste produced by the commercial sector that is collected 9
under an arrangement between the waste producer and a private-sector waste manage- 10
ment company. This means that such waste falls outside the definition of municipal 1
solid waste. In terms of composition it is similar to household waste, but tends to 2
contain more paper and card products and less food and garden waste. Of course 3
there are exceptions to this and some sectors produce large quantities of food waste. 4
5
Agricultural waste Agricultural waste covers a wide range of materials, from scrap
6
machinery to manure. Until recently, agricultural waste disposal was largely unregu-
7
lated, but now, with the exception of crop residues and animal manures, agricultural 8
waste is subject to the same controls as industrial and commercial waste. The manage- 9
ment of plastic films, fertilizer containers and other farm chemical drums is a particular 20
problem in this area. 1
2
Biodegradable waste This definition cuts across all of the above categories (except inert
3
waste) and comprises any waste that can be broken down by microbial action. This
4
microbial decomposition takes place in landfill sites leading to the generation of poten-
5
tially polluting landfill gas and leachate (a liquid that collects in the base of landfill
6
sites and, if allowed to escape, can cause serious pollution to water courses and
7
aquifers) . For this reason the Landfill Directive is restricting the landfilling of
8
biodegradable municipal waste.
9
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Activity
1
Do you know how many and how much of the above types of waste were produced 2
at your workplace over the past 1 2 months? Establishing and maintaining a list or 3
waste inventory can be extremely useful. Locate or create such an inventory for your 4
own use – you will be able to arrange information in the following chapters more 5
effectively. 61
12
2.4 How much waste do we produce?

In total, the UK produces about 420 million tonnes of solid waste each year. This can
be broken down as shown in Figure 1 .
Much of this waste has relatively low potential for environmental damage. For example,
quarrying and mining waste is largely inert, dredging spoils are disposed of at sea, and
a lot of agricultural waste is recycled on the farm. Having said that, even if we only
concern ourselves with industrial, commercial and municipal waste, we still have over
1 00 million tonnes of waste a year to consider.
Local authorities are now producing reliable estimates of the amount of municipal waste
produced and how it is managed, but there is less information available on commercial
and industrial waste. The Environment Agency undertook a survey of industrial and
commercial waste in England and Wales for the year 2002–03 and the information below
is taken from that survey (full details are available at http://www.environment-agency.
gov.uk) .
It was estimated that England and Wales produced around 42 million tonnes of indus-
trial and 31 million tonnes of commercial waste in 2002–03 (Scotland produces about
2 million tonnes each of industrial and commercial waste and Northern Ireland about
700,000 tonnes of commercial and industrial waste in total) . The composition of this is
shown in Figure 2. It can be seen that the main component of industrial waste is mineral
waste (mainly power station ash and slags from iron and steel works) , while commer-
cial waste is mainly mixed waste (explained further below) and non-metallic material
(mainly paper and card) .
Figure 1: Waste
production in the UK
I n d u stri al
Ag ri cu l tu re
1 6%
1 8%
C o n stru cti on an d
d em ol i ti o n
1 7% M i n i n g & q u arryi n g
1 8%
C o m m erci al
4%
S ewag e sl u d g e
M u n i ci p al
8%
7%
D red g i n g sp o i l s
1 2%
13
Figure 2: Industrial (a) and (a) Chemical 1

commercial (b) waste 1 4%
2
composition
Metallic 3
7%
Mineral 4
38%
5
Non-metallic 6
1 3%
7
Discarded equipment 0% 8
Animal/vegetable Sludge 9
material 2%
1 0% Mixed waste 10
1 6%
1
2
(b) Mineral
Chemical 3% 3
6% Sludge 1 %
Metallic 2% 4
7
Non-metallic
28% 8
Mixed waste 9
52%
20
Discarded equipment 1 %
1
Animal/vegetable 2
material
7% 3
5
A survey carried out in Wales found that the main components of mixed commercial
6
waste were paper and card (41 %) and kitchen and garden waste (23%) , as shown in
7
Figure 3.
8
But what happens to this waste? The Environment Agency survey shows an encouraging 9
situation, with 43% of our commercial and industrial waste being either reused or recy- 30
cled. The figures are particularly good for metallic and non-metallic waste at 92% and 1
85% respectively, but there are areas where improvements can be made. The mixed waste 2
recycling figures are 1 2% for industrial waste and 8% for commercial waste. This is not 3
surprising; once wastes become mixed, contamination is likely to occur, reducing the 4
uses and value of any recovered material. The mechanical and human effort required to 5
separate materials from mixed waste also increases the cost of the recovery process. 61
14
Other Figure 3: Mixed

non-combustible commercial waste
waste composition
Other 11%
combustible
waste
6%
Metals
5%
Paper
41 %
Kitchen
and garden
waste
23%
Glass Plastics
4% 1 0%
In summary, the message is clear. The UK produces large amounts of commercial and
industrial waste, and substantial quantities are being recycled and reused. However, there
is still much progress to be made, particularly with mixed waste.
15
1
10
20
30
61
Why bother with waste? 3
Summary
There are several pressing reasons why businesses of all sizes, regardless of their
business activity, need to bother with waste.
Perhaps the most important reason – and the one that affects senior management
on a personal level – is the legal one. For example, under the Environmental
Protection Act (1 990) , companies can face unlimited fines and individuals can be
imprisoned for up to two years for failing to comply with their ‘duty of care’ when
it comes to waste.
The management of several other types of waste is also tightly regulated. If you
produce any of the following, you must be aware of your legal responsibilities:
• 50 tonnes or more of packaging waste a year;
• hazardous waste (including fridges and freezers, fluorescent light tubes etc) ;
• waste electrical and electronic equipment;
• scrap vehicles.
Secondly, there can be important financial savings for firms that bother about their
waste.
You pay for your waste three times over; in buying the raw materials, in adding
value to those materials and in throwing away the final waste. The final cost of waste
can be 5–20 times the waste disposal fees, and until you have detailed information
about your own waste production, you simply won’t know where the costs to your
organization could be within that bracket. In this competitive world, being seen to
bother about your waste can have important commercial advantages. Remember
that many waste reduction measures cost nothing to implement (except perhaps a
little time to organize) and every pound saved on material costs and waste disposal
goes straight to the bottom line. Even more importantly, reducing waste-related costs
could have a positive impact on an organization’s cash flow, giving the firm a greater
17
1
opportunity to expand, especially those that do not have access to alternative inward
2
investment sources.
3
Thirdly, bothering with your waste can have several market advantages. 4
5
Many large firms will only deal with suppliers that have a waste policy or certified
6
Environmental Management System (EMS) . Waste generation and its management
7
are key aspects of an EMS.
8
Potential investors, existing and future employees, banks, insurance companies and 9
consumers are all likely to look more favourably at firms that have an EMS and 10
waste policies in place. 1
2
Finally, the way we deal with our waste can have a tremendous effect on the envi-
3
ronment. This is true whether you are a one-person operation or a multinational
4
company. Reducing waste or sending waste for recovery rather than disposal can
5
save materials and energy and reduce environmental pollution.
6
3.1 I n trod u cti on 9
20
There are several pressing reasons why businesses of all sizes, regardless of their busi-
1
ness activity, need to bother with waste. The four main reasons often cited are:
2
3
• legal;
4
• financial;
5
• commercial;
6
• environmental.
7
8
These are discussed in sections 3.2 to 3.5. At first sight, implementing the measures
9
suggested may seem like a lot of work for no benefit. However, a variety of studies have
30
shown that companies that actively reduce environmental risks and impacts are more
1
sustainable, profitable, valuable and competitive. Dealing actively with your waste can
2
improve your profitability and give you distinct commercial advantages. The days of
3
paying for someone to take it away and forgetting about it are realistically at an end.
4
Successful enterprises must have an eye on the future. Making predictions about what 5
will happen in the future is always difficult, but we can be reasonably certain that the 61
1 8
3. WH Y B OTH E R WI TH WASTE?
legislation governing waste and the environment as a whole will become tighter as time
goes on.
The government published a draft waste strategy for England in February 2006. This
consultation document2 proposes several targets to reduce the amount of waste sent to
landfill. Currently, about half of our commercial and industrial waste is landfilled and
it is proposed to reduce this to 37% by 201 0 and to 35% by 2020. The message is clear:
you should expect waste disposal charges to rise as relatively cheap landfill is replaced
with more costly recycling and recovery processes.
Chapter 5 discusses the Landfill Directive which, among other things, is restricting the
amount of biodegradable municipal waste that can be sent to landfill. However, there is
an inconsistency over the UK’s interpretation of the directive that can be illustrated by
taking the case of a small office-based business. If the office’s waste is collected by the
council (or its contractors) the waste is classed as ‘municipal waste’ and is governed by
the directive. On the other hand, if the same waste is collected by a private contractor
working for the company concerned, the waste is classed as ‘commercial and industrial’
waste and is not covered by the directive. Regardless of the legal definition of the waste,
it still has the same potential to cause environmental pollution if it is landfilled. So, it
is possible that, in the future, the directive will be extended to cover all solid waste. If
this happens it will become harder to dispose of your waste, and the financial and other
pressures to reduce, reuse and recycle will increase.
If you handle more than 50 tonnes of packaging waste a year you will already be covered
by the system known as ‘producer responsibility’. Under producer responsibility,
companies that manufacture or use packaging or sell packaged goods are jointly respon-
sible for carrying out or financing the recycling of packaging waste. Producer
responsibility is currently being extended to cover vehicles, electrical and electronic equip-
ment, and there are voluntary schemes for newsprint, direct mail and magazines. This
trend could continue; in the longer term we could see further growth in producer respon-
sibility schemes. In short, if your firm makes or sells a product you could be responsible
for its final disposal!
2 Department for Environment, Food and Rural Affairs (2006) , A Review of England’s Waste Strategy – A
Consultation Document.
19
3.2 Keeping on the right side of the law 1
The most important reason for being concerned about the amount of waste you produce 3
and how it is managed or disposed of is that, put simply, you don’t have any choice in 4
the matter. Chapter 5 provides a practical overview of key UK waste legislation, but one 5
piece of legislation is worth repeating; namely Section 34 of the Environmental Protection 6
Act (1 990) . 7
8
Under this act, every business in England and Wales has a legal Duty of Care to ensure 9
waste is disposed of responsibly. If your company either directly or indirectly ‘causes or 10
permits’ a polluting material to enter the environment, then your company can be pros- 1
ecuted. If your waste contractor handles your waste illegally, again your company is 2
responsible and you will be prosecuted. 3
5
As far as this legislation is concerned, disposal usually means that the waste has been
deposited in a landfill site and recovery means that the waste has been incinerated or 6
reached the output stream of a recycling or composting system.
7
9
You cannot transfer this responsibility to a third party. If your waste ends up fly-tipped
20
in a local lay-by, burned in a disused industrial estate or landfilled in an unlicensed site
1
you are still responsible. The penalties can be severe. Successful prosecution and convic-
2
tion on indictment can lead to: 3
4
• an unlimited fine for the company;
5
• up to two years’ imprisonment and/or an unlimited fine for the responsible managers.
6
7
Remember that ignorance is no defence. It is your responsibility to 3 :
8
• keep records of the weights and types of waste produced; 9
• provide an accurate description of any waste that you transfer to any other firm; 30
• keep records of how each load of waste is managed and who it is transferred to; 1
3 These points should be regarded as an indicative list. For full details of your obligations under duty of care, 5
you should consult the Code of Practice issued by the Department for Environment, Food and Rural Affairs
(DEFRA) . 61
20
• keep invoices, weighbridge tickets and receipts from any site you take waste to your-
self;
• keep weighbridge tickets and receipts from any firms that collect your waste (including
waste collected for recovery or recycling);
• obtain evidence that any firm that collects your waste has the necessary licences to
transport wastes;
• obtain evidence (weighbridge tickets and receipts) that waste collected on your behalf
is taken to a waste management facility that has the necessary licences and permits
issued by the National Regulator4.
This may sound like a major task, but much of the information will already have been
collected by your accounts or finance department. Any responsible waste collection and
management companies you use will be more than happy to provide the evidence neces-
sary to establish their bona-fides.
‘Duty of Care’ applies to all types of waste, but there are other important pieces of legis-
lation that you must comply with if you:
• generate or dispose of hazardous waste (until 2005, this was known as ‘Special Waste’
in England & Wales and you may still see the latter term used in some official docu-
ments from other parts of the UK);
• dispose of waste electrical and electronic equipment (often referred to as WEEE) ;
• dispose of ‘end of life vehicles’ (scrap cars, vans, lorries etc – often referred to
as ELV) ;
• are involved in the packaging supply chain and handle more than 50 tonnes of
packaging a year or have a turnover above £2 million per year.
The regulations covering the management of these wastes is summarized in Chapter 6.
If you think you are likely to be affected by this legislation you should consult your
National Regulator. Contact details for the National Regulators are given in Chapter 8.
4 In England and Wales the Environment Agency is the National Regulator, in Scotland and Northern Ireland
this role is taken by the Scottish Environment Protection Agency (SEPA) and the Environment and Heritage
Service respectively.
21
Examples of offences 1
from the Environment A person was fined £21 ,000 plus £6,000 costs for running an illegal waste transfer
station and landfill site. 2
Agency
A building contractor was fined £1 ,500 (under duty of care) for describing the 3
contents of a skip containing several paint containers as ‘builder’s rubble’. 4
A business was fined £4,500 and one of its directors was fined £2,250 after drums 5
of varnish were deposited on its forecourt site.
6
A brewery was fined £21 ,000 with £1 ,750 costs for offences relating to depositing
waste on unlicensed land and in a manner likely to cause pollution. 7
After a series of offences including illegally depositing chemical waste, supplying false 8
or misleading information and failing to provide waste transfer notes, an individual was 9
sentenced to 1 8 months in prison.
10
© Crown Copyright Environment Agency Website 2006
1
3
3.3 The financial drive 4
5
Research done by the Open University in 2000 estimated that for every person employed
6
in the UK, £650 per year is spent on disposing of waste produced by commerce and
7
industry. There are many more beneficial ways in which this money could be spent, for
8
example reducing prices, increasing profits, increasing wages and safeguarding jobs. So
9
whether you are an employer or an employee, you have ample reason to be concerned
20
with how your waste is managed.
1
You may well think that ‘my firm only produces a small amount of waste so I needn’t
2
worry’. Well, it is possible that this is the case, but you must take account of the fact
3
that, when it comes to waste, you pay for it three times over.
4
Firstly, you obtain a raw material and pay your supplier. 6
Secondly, you make something from the raw material or add value to it in some way 7
and pay for the labour, energy or materials that have been used to add the value.
8
Finally, you throw the waste away and pay your disposal contractor.
9
30
Envirowise (a Government-funded centre providing free environmental advice to busi- 1
nesses) states that you should think of waste not only in terms of what you produce in 2
your ‘dustbin’, but also in terms of reducing production, use or disposal of anything that 3
isn’t reused or sold by your business. Another company shifted its perspective to the 4
point where it looked on all its outputs as ‘product’, adding ‘we just don’t get paid for 5
all of it’. It made it look at what it did through new eyes. 61
22
If you are still not convinced, look at the following example.
Walton Consulting Ltd is a service-sector company and its main product is the informa-
tion contained in the reports provided to its clients. The company buys 1 1 tonnes (or
4,200 reams) of printer paper a year at a cost of £850 per tonne. Of this, 30% ends up
in reports delivered to clients, letters sent out and information retained by Walton’s staff.
The remainder is collected along with Walton’s other waste by a waste management
company. This company charges £30 per tonne collection and disposal charge plus the
landfill tax at a rate of £1 8 per tonne (the rate from April 2005) . How much is this
costing Walton Products each year?
The simplest answer is to look at the disposal charge and tax, which works out at:
amount bought ? percentage landfilled ? (disposal cost ? tax)
11 ? 70
___ ? (30 ? 1 8)
1 00
? £370 per year (to the nearest £)
A modest enough sum.
But, this paper has been printed in a laser printer or a photocopier at a cost of 3p per
sheet. The number of sheets of paper that Walton’s staff throw away each year is:
number of reams brought ? sheets per ream ? percentage waste

or
4200 ? 500 ? 70
___ ? 1 ,470,000 sheets per year
1 00
The cost of printing this paper is 3p per sheet, so the cost of printing the scrapped paper
is:
1 1 ,470,000 ? 3
___
1 00
? £44,1 00 per year
This ignores the cost of the time taken to do the photocopying, collect the printing from
the printer, keep the printer trays filled with paper and empty the waste paper baskets.
To this we can add the purchase price of the paper that is thrown away (which costs
£850 per tonne) , which comes to:
11 ? 70
___ ? 850 ? £6,545.
1 00
So the total cost to the firm of this waste paper is:
£370 ? £44,1 00 ? £6545 ? £50,938
23
TR E N D S AN D B EST PRACTI CE I N WASTE M AN AG E M E N T
Of this £50,938, only 0.7% is represented by the waste disposal fee and 87% of the total 1
is due to the cost of printing the paper. To some extent, this figure is an exaggeration 2
because some of the printing will be necessary even if the paper is eventually thrown 3
away. For example, reports to customers will have to be printed in draft form and checked 4
before producing the final documents, and the operation of the company will require 5
the production of documents that are ultimately thrown away. Of course, if your busi- 6
ness manufactures goods from raw materials, the processing costs of products that have 7
to be scrapped rather than sold could be much greater than the 3p per sheet processing 8
costs in this example. 9
10
However, regardless of your business activity, the message is clear. Waste management
1
charges may only represent a small fraction of the true cost of your business inefficiencies.
2
3
Activity 4
Find out how much paper your organization buys each year, your printing costs, the 5
disposal costs and then calculate how much this is costing your company per year. If 6
you work in a manufacturing company, you could try doing the same for one of your 7
products or a part of one of the products. 8
By developing a practical waste management strategy – as set out in Chapter 5 – many 20
organizations could take measures to reduce their consumption of paper and other 1
resources. For now, just bear in mind the following points. 2
• Taking into account raw material costs, processing, labour and energy costs, 4
the real price tag on waste is generally 5–20 times the waste disposal fees. 5
• Many waste reduction measures cost nothing to implement. 6
• A company-wide resource (materials, energy and waste) efficiency programme 7
will typically save £1 ,000 per employee per year. 8
• A systematic waste minimization programme could save 1 % of turnover. 9
• Every pound saved on material costs and waste disposal charges goes straight to 30
the bottom line. 1
You should note that we are not necessarily talking about recycling here. Recycling has 3
its own environmental impact. It is far better, from both the environmental and finan- 4
cial points of view, to avoid producing material that needs to be recycled in the first 5
place. 61
24
3.4 Commercial pressures

Commercial pressures are significant and growing. Consider the quote from a prospec-
tive tenderer for a government job set out below.
“Recently I prepared a tender to carry out some work for a large government department.
Before I was allowed to submit a tender I had to supply the department with a copy ofmy organ-
ization’s environmental and waste policies. Without such policies we would have been unable to
tender. This is becoming common practice among government departments and large companies.
The message is clear: if you want the work you need to show that you have thought about your
waste.”
Manager of a large research organization
Many organizations have learned the benefits of adopting an environmental manage-
ment system (EMS) under the ISO 1 4001 or BS 8555 standards, or registration under
an accredited Eco-Management and Audit Scheme (EMAS) 5 .
These advantages include the following.
• Customers that have an EMS or EMAS often require or favour suppliers that are also
certified.
• The Environment Agency determines the frequency of visits to the processes that it
regulates under the system know as Operator and Pollution Risk Appraisal (OPRA) .
Firms with an EMS could potentially receive fewer visits than similar firms without
one.
• Certified firms are less likely to cause pollution incidents and, if they do occur, are
more likely to be able to minimize the impact of any incidents.
• The EMS or EMAS process helps firms identify areas where energy and material are
wasted, leading to improvements in resource efficiency and hence a reduction in costs.
• Potential shareholders are more likely to invest in a certified company than an un-
certified company. Similarly, banks and insurance companies are likely to treat
EMS-certified companies more favourably.
• The existence of a certified environmental management system such as ISO 1 4001 ,
EMAS or BS 8555 provides internal and external reassurance of effective working. It
can also be used by a business for publicity purposes.
5 See Chapter 6 for details of these schemes
25
Environmental management systems do not prescribe specific standards for dealing with 1
waste (or indeed any other potential pollutant) , but they do require the adoption of a 2
culture of continual improvement. As part of the EMS, a company would have to: 3
4
• identify all sources of waste and the size and composition of each waste stream;
5
• investigate and implement practicable ways of reducing waste through changes to the
6
processes and raw materials used;
7
• investigate and implement practicable ways of reducing the environmental impact of
8
the unavoidable waste generated.
9
In short, if your organization wishes to obtain certification under an EMS or EMAS, it 10
must take waste management issues into account. 1
2
Many businesses have recognized the competitive edge that good environmental policies
3
and practice gives them, and as a result have joined a variety of business clubs and
4
networks with this in mind.
5
6
One such organization, ‘Business in the Community’ (BITC) , has some interesting points
7
to make about environmental performance and business. It states that in its experience,
8
consumers, business contractors and suppliers prefer companies with a ‘clean record’.
9
As companies become larger and competition to supply them increases, individual
20
purchasers have become more powerful and demanding. As a result, there will be an
1
increasing requirement for suppliers to demonstrate that they offer not only good value
2
for money, but also zero risk (www.bitc.org.uk) .
3
Environmental issues can substantially affect risk. A recent opinion poll found that 85% 4
of all UK adults think that the environment is very important for socially responsible 5
businesses. BITC also points out that it is a condition of insurance cover in some busi- 6
ness sectors that an environmental audit is carried out – and this is spreading to more 7
business sectors year on year. 8
9
Finally, don’t forget that the waste you physically produce is not the beginning or end
30
of the chain.
1
“The green customer wants to know whether your products, your manufacturing techniques and 2
your company policies take environmental impact into account – and incidentally will expect you 3
to ask those very same questions of your suppliers in turn. Ultimately, all of these reasons affect 4
the bottom line; all of them, therefore, make good business sense.” 5
Sir Anthony Cleaver, former Chairman IBM UK 61
26
As an environmentally responsible company you may also ask the same of YOUR
suppliers. If your company is found to be buying from an irresponsible operator who is
then prosecuted, your name could, in turn, become tarnished by association. Your
investors could lose confidence in your business, which could affect its value.
3.5 Environmental aspects

You may be wondering why we’ve left the environment to the end of this section. So far,
we have looked at reasons imposed on you by the law, by your financial controls and by
your customers and potential customers. At this point we consider the subject of waste
management from a more altruistic point of view. We suggest that you should bother
with waste because ‘it’s the right thing to do’.
Also consider the future. As well as looking after our own needs, we have a moral duty
to be concerned about people yet to be born. If we know that something we are doing
will create a problem that must be solved in 50 years’ time, we need to question whether
it is right to be doing it.
Firstly, let’s think about the main disposal method for waste in the UK: landfill. It is
important to stress that landfill has been carried out for centuries and the science and
technology involved are well understood. You must also bear in mind that landfills are
tightly regulated and operated to extremely high standards. Having said that, we must
consider the following:
• Landfills produce leachate (a liquid that can contain high levels of organic contamin-
ants, heavy metals and salts) as the biodegradable components in the waste break
down. If leachate escapes from a landfill site it could, in the worst case, pollute flowing
underground water (aquifers) and rivers that could otherwise be used as drinking
water supplies.
• As well as producing leachate, decomposing waste generates landfill gas, a mixture of
methane and carbon dioxide. Methane is a powerful greenhouse gas contributing to
global climate change (or global warming) . Current evidence suggests that global
climate change is leading to unstable and changing weather patterns that may have
serious impacts on food production and the continued existence of low-lying areas
of land. Landfill gas is captured and used to generate power, but the collection systems
are not 1 00% efficient so all landfilled biodegradable waste (remember that this
includes paper) contributes to global climate change to some extent.
27
• Today’s landfills are expected to remain active (producing leachate and gas) for many 1
decades, or even centuries, after the site has been closed. So we have to try to be cer- 2
tain that financial, managerial and technical measures will be available to care for the 3
site for (say) 1 00 years. We also need to accept that we will be asking future genera- 4
tions to put right any problems that may occur as a result of today’s landfill practices. 5
How do you plug a hole in a membrane liner situated below a million tonnes of waste? 6
7
Other waste management operations also have the potential to cause pollution.
8
• Incinerators emit nitrogen oxides and other gaseous pollutants and produce residues 9
that require disposal in hazardous waste sites. 10
• Recycling facilities can generate local dust (which might be biologically active) , noise 1
and odour problems and there are concerns about the impact of the operation on 2
the health of its employees. 3
• Composting sites can release biologically active dusts and odours. 4
5
All waste management sites create additional traffic in the local area and can be visually
6
intrusive. They are rarely considered to be ‘good neighbours’ and, rightly or wrongly,
7
planning applications for new facilities are almost always opposed.
8
Having said this, recovering materials and energy from waste can have several environ- 9
mental advantages. 20
1
• Making newsprint from recycled fibre uses 30% less energy than newsprint manu-
2
factured from virgin wood.
3
• A 1 0% increase in the amount of waste glass added to a glass-making furnace reduces
4
energy consumption by 2.5%, particulate material emissions by 8%, nitrogen oxides
5
emissions by 4% and sulphur dioxide emissions by 1 0%.
6
• Every tonne of steel produced from scrap steel saves 1 .5 tonnes of iron ore and 0.5
7
tonnes of coal, as well as reducing water and limestone use.
8
• Making aluminium cans from scrap achieves a 95% saving in energy use in compar-
9
ison with aluminium production from the raw material bauxite.
30
• Burning one tonne of waste in a modern incinerator generates enough power for
1
3,500 showers, and also produces 40 kg of iron and 3 kg of aluminium for recycling.
2
Anything that a business can do to reduce the amount of waste that has to be managed 3
in the first place is the best environmental option. Failing that, reducing the impact of 4
the waste that is produced should be considered – especially when the measures taken 5
also give some of the advantages discussed above. 61
28
3.6 Wh at sh ou l d I d o wi th m y wa ste?
Sections 3.2 to 3.5 give suggestions about how businesses can deal with their wastes in
general, but how should a particular firm decide what to do? In the short term, the
simplest answer may be to do what ever is cheapest. This approach may provide a tempor-
ary solution, but, as you will see in Chapter 6, in the longer term you will need to take
much more regard of the environmental impact of your waste.
The European Waste Hierarchy was originally developed by the European Union and
underpins all waste-related legislation and the UK’s waste strategies. The hierarchy is
shown in Figure 4 and the aim is to select waste management solutions that are as close
to the top of the hierarchy as possible.
• If you don’t generate waste in the first place it doesn’t need to be managed at all, so
‘reduction’ takes first place in the hierarchy. Can my manufacturing process be adjusted
to reduce the waste by-products, can my office reduce the amount of printing that
takes place?
• If you can re-use a waste item it means that you have at least two opportunities to
make the most of a product before it is disposed of. Can old furniture or equipment
be used by charities or can waste paper be used for writing internal memos and lists?
Figure 4: European waste

hierarchy
Reduction
Reuse
Recovery
recycling
composting
energy
Disposal
29
• Some waste is inevitable, but some use can be made of much of it through ‘recovery’ 1
– be it sending paper, metals or glass to a merchant for recycling, sending garden 2
waste to a composting scheme or sending non-recyclable waste for energy recovery. 3
• Finally, waste that remains needs to be disposed of, and this would usually be by land- 4
fill. 5
6
The hierarchy provides a useful guide, but you still need to take care. Managing waste 7
is all about protecting people’s health and the environment and this needs to be borne 8
in mind. Before engaging in any reuse or recovery option you should ask yourself the 9
following questions. 10
1
• Does transporting the waste to the recovery operation and the recovered products
2
back to industry consume more energy than the process saves?
3
• Does the recovery operation generate any pollutants and waste itself, and how are
4
these dealt with?
5
• Does the recovery process operate to the health and safety standards that you require
6
in your workplace? ( This is particularly important if waste is being processed in devel-
7
oping countries where health and environmental standards may be much lower.)
8
• If you are separating out materials, what space and storage issues do you need to
9
consider? Previously hazardous components of waste may have been ‘diluted’ in the
20
general mix – new separation requirements lead to the need for safe storage to ensure
1
certain types of wastes that could react with each other do not mix.
2
30
61
30
How to manage waste 4
Summary
This Chapter provides the tools and techniques to quantify what is happening or
not happening in the business in terms of waste management. To make sense of
waste management you need to understand what is going on in the organization
and be able to answer such questions as the following.
• How much is waste actually costing the business? Remember, government figures
indicate that waste costs add up to approximately £650 per employee. Do the
maths and consider that this is bottom line haemorrhaging of profit too.
• Where are we producing waste, what is it and why are we producing it?
• How many people are involved in dealing with this waste and how are they dealing
with it?
• How much is the extra raw material that we convert to waste costing us and how
much are we paying to dispose of it?
The core of this chapter is a detailed and practical waste review to provide in-depth
understanding of waste issues in the business. Good practice builds from this under-
standing so that informed management decisions can be made to develop an effective
waste management strategy.
This Chapter is supplemented by Appendix 1 , which provides a series of checklists
to help you carry out a detailed waste review.
Later, in Chapter 6 we will discuss waste management in the context of other manage-
ment systems such as quality of health and safety.
31
To really understand your waste, and the implications for your organization, you have 1
to get close to it. 2
3
“There was an awareness issue. We needed to take groups of people from the factory floor around
4
our effluent treatment plant to explain the implications ofordinary everyday actions and how they
5
could make a difference.”
6
Manager, food products company
7
In this quote, it really did mean getting close to see first hand what waste was being 8
generated and where this waste arose. Making sense of waste management is about making 9
the connections between day-to-day activity and waste generation. To make this connec- 10
tion you need to: 1
2
• understand what causes waste in the first place;
3
• accept that waste equals lost profit and that as part of effective management you
4
should be working to eliminate or reduce your waste.
5
6
4.1 What is effective waste management? 7
8
Taking responsibility for your waste, at all stages from production to disposal, is a legal
9
requirement.
20
1
The Environment Agency website lists recent fines and prosecutions adding up to over 2
£578,000 with community service and custodial sentences for some offenders.
3
5
For business, this might mean reducing the raw material inputs to make a product and
6
as a consequence increasing profitability.
7
There are four key actions to effective waste management: 8
9
1 . Responsibility
30
Ensure that someone in your organization has overall responsibility for waste. This will 1
include an understanding of pertinent legislation. 2
3
2. Communication 4
Talk with the people in the organization who create and control the waste. They will 5
often have excellent ideas on how measures could be taken to reduce or eliminate it. 61
32
4. H OW TO M AN AG E WASTE
3. Review
Take stock of the waste created by your organization and find out the quantity and cost
to the organization in terms of product and disposal. ( We deal with waste review in
more detail later. )
4. Be systemic
It is important to consider the whole rather than j ust parts of the business. Make sure
you have systems in place to address waste management issues throughout the organ-
ization.
“I’ve been very struck by a story about when Japanese engineering students are trained and they
don’t have the concept of waste as we do when they are producing their calculations. They simply
do not allow for waste. It’s either lost profit – and you avoid it – or it’s a resource for somebody
else.”
Alison Austin, Sainsbury’s plc
Activity
Consider these four key actions. What, if anything, do you already know?
Key action area What do you know?

1 . Responsibility
Who in your organization has responsibility for waste?
What are the applicable regulations or any other
requirements?
Do you meet them?
2. Communication
Do you know who creates waste in your organization?
Do you know who your regulators are?
3. Review
What information already exists regarding waste?
Who keeps it?
4. Be systemic
Are any systems already in place?
What are they, how do they operate and who
operates them?
33
4.2 A waste review 1
If you can’t measure it then you can’t manage it effectively. 3
4
A review is simply a preliminary stock check of waste in your organization against which
5
future progress can be measured. It provides the essential baseline and a system for effec-
6
tive waste management. A waste review will enable you to set out a plan of action with
7
business-based priorities and targets clearly identified, and to do this with confidence as
8
it will be based on organizational reality.
9
10
The seven steps to effective waste management
1
Working systematically through the seven steps set out below provides a comprehensive 2
waste review for your organization. The detail and depth for each step will vary from 3
organization to organization, but the steps remain the same. When you have completed 4
all seven steps you will be in a position to answer with confidence the questions raised 5
in the beginning this chapter. 6
8
Figure 5: The seven steps
to effective waste Step 1 - Commitment 9
management M aki n g su re you r o rg an i zati o n
20
i s com m i tted t o a waste
m an ag em en t p rog ram m e
1
3
Step 7 - Action, monitoring Step 2 - Scope and
and follow up preparation 4
Th e p racti cal step s to b ri n g th e revi ew Th e g ro u n d wo rk to en su re th e revi ew
5
to l i fe an d m ake th e work p ay off. ach i eves wh at you wan t i t to . Wh y d o yo u
wan t to carry ou t a wast e revi ew? Wh at

6
I n teg rati n g th e work wi th you r
m an ag em en t p rocesses d o yo u wan t t o d o? H ow m i g h t yo u d o i t?
8
Step 6 - Policy Step 3 - Issues and information 9
Fo rm al i zi n g yo u r co m m i tm en t C ol l ecti n g th e d at a for you r
to sou n d waste m an ag em en t b u si n ess. Th e wast e trai l 30
2
Step 5 - Reporting Step 4 - Evaluation
Letti n g th e b u si n ess kn ow wh at i s M aki n g sen se of th e d ata you 3
g oi n g o n an d yo u r fu tu re exp ectati o n s h ave co l l ected
61
34
Step 1 – Commitment
This is the critical first step. Senior management approval and commitment is essential
if effective waste management is to take root and flourish in the organization. Think
about the messages you need to use to ensure ‘ buy in’ from senior management.
Examples of messages
Legal – ‘Failing to comply with applicable waste legislation will ultimately result in
prosecution and damage to our reputation with the likelihood that we will lose
business.’ Visit the Environment Agency website and find relevant examples to
incorporate in your briefing of senior management. For example: illegal scrapyard
operators were the subject of four court cases after a raid on their sites last year..
Fines totalled £1 0,000, with an additional 300 hours of community punishment orders
and nearly £4,000 in court costs, after Operation Underscore took place following
months of careful planning between the Environment Agency, West Midlands Police
and Wolverhampton City Council. Let’s hope these are not your waste contractors!
Cost – do the maths and provide some examples of quick wins. Again, provide
industry-specific examples by visiting the Envirowise website. Example: replacing
conventional cardboard packaging with reusable plastic containers has helped a
pharmaceutical company save £39,000 per year after investment costs.
Environment – remind senior management that customers now require businesses to
meet increasingly stringent environmental requirements (perhaps related to ISO 1 4001
or BS 8555). Example: supplying braking system components for the automotive
industry has helped Continental Teves Ltd save over £81 ,000 per year and reduce
waste. Continental Teves has actively and successfully encouraged its suppliers to
adopt similar practices and switch to reusable packaging.
Community – being a good neighbour is an increasingly essential part of business
practice. In its report ‘Tomorrow’s Company’, the Royal Society of Arts, Commerce &
Manufactures refers to a range of stakeholders, including the local community and
staff, as signing a business’s licence to operate. By this it means that not behaving
responsibly will ultimately result in eroding of business viability and eventual shut
down Example: Severn Trent Laboratories Ltd eliminated a solvent washing procedure,
.
saving £7,000 per year through solvent purchasing and disposal costs. Other benefits
included lower levels of employee exposure to organic solvents and smaller volumes of
hazardous waste requiring disposal.
Step 2 – Scope and prepare for the waste review

This step involves answering five basic questions from an organizational perspective.
Q1 . Why bother with the review?
Earlier chapters of this guide set out the rationale for effective waste management and
should have convinced you of the regulatory and efficiency arguments for carrying out
a waste review. Conducting a review will provide a planned and systemic management
response to these and help you focus on priority areas for action.
35
Q2. What can we expect to get out of a waste review? 1
The review will help to identify current waste practices throughout the organization and 2
any learning from past experiences. Direct outcomes are likely to include: 3
4
• compliance – confidence that your organization complies with existing waste regula-
5
tions and will be able to adopt future legislation with confidence;
6
• savings – identify areas where you can start to save money and potentially improve
7
competitive edge;
8
• impacts – understand and quantify your greatest waste impacts and reduce any asso-
9
ciated risks;
10
• policy – the baseline understanding to draft an effective organizational policy for waste
1
management;
2
• action – the information to set up an action plan to bring the review to business-
3
focused life.
4
Q3. Where should we concentrate our efforts? 5
The review will allow you to focus on those areas of waste management that need atten- 6
tion and those that present the best opportunities for the organization. The checklists 7
in Appendix 1 provide one mechanism and a focus for the waste review. 8
9
Q4. Who needs to be involved in the review?
20
Carrying out the review in isolation from other key staff is a sure way to make imple-
1
mentation of a waste strategy hard work later on. Teamwork is paramount for success.
2
Your ‘team’ should be drawn from inside the organization, and outside expertise plugged
3
in as appropriate. For example, you might want to open up a dialogue with your regu-
4
lators.
5
Whatever you do, make sure: 6
7
• that senior management are involved in the process;
8
• that you have access to specialist skills as required;
9
• that staff know what you are doing and why you are doing it, in ways that they under-
30
stand;
1
• that staff know what expectations you have of them and how you want them to involve
2
themselves in the process.
3
Q5. How should I plan the review? 4
You and your team need to decide the scope of the waste review. Will it cover all orga- 5
nizational functions, from offices to transport? Will you focus on some professional 61
36
judgement priority areas first? Will you look at a specific site or sites? Will you focus on
one or two areas – a partial review – and build up the big picture over time?
The basic questions to ask are as follows.
• What areas are we going to review?
• What information do we need and how best can it be gathered?
• What information already exists? Where is it and who keeps it?
• What is a realistic time frame for the review?
• What resources do we have available – that is, internal expertise and records, and rela-
tionships with external sources of guidance?
• How will I communicate with key staff and staff in a wider sense?
The ideas in the activity below will help you build a project outline for the waste review
and prioritize issues that you feel need attention in your organization. Develop your own
working version of this table.
Activity
Using the table below, jot down some benefits you want to get out of the waste review:
1.
2.
3.
4.
Before you move to Step 3, hold a briefing meeting with key internal staff and formalize
how you are going to communicate in the widest sense. Staff commitment and involve-
ment will help ensure success. Your first briefing meeting might well be part of a general
management briefing. Draft a short paper to cover:
• why the organization is carrying out a waste review;
• what is planned, perhaps including your version of the benefits table from the activity
above;
• the benefits the organization will gain from the review;
• the practicalities of the waste review.
37
Step 3 – Issues and information gathering 1
2
You have now reached the point where the ground has been set out and key staff are on
3
board. It’s now time to carry out the review.
4
Think carefully about how you and your team plan to conduct the review and use the 5
checklists in Appendix 1 to help you. 6
The checklists cover eight activity areas, which are set out in Table 3. This is intended 8
to help you prioritize which of these areas you need to start with. Some areas will need 9
more work and perhaps advice and guidance from external sources such as your regu- 10
lators. 1
2
Table 3 illustrates a range of business activities that you may need to consider. To show
3
how it might look when completed, we have filled in some of the questions you might
4
use for each area. The rankings are based on a simple scoring system where 1 = lowest
5
potential for business benefit and 5 = greatest benefit. Deciding which area should be
6
scored higher than another will be based on business judgement; a simple way to prior-
7
itize is to quickly consider four generic questions for each area. Based on your informed
8
professional response you should be able to rank each area.
9
20
The generic questions to consider are as follows.
1
1 . How much raw material do we use (for a unit of production) ? 2
2. How much energy and water do we use? 3
3. How much waste do we produce? 4
4. How much does this cost us? 5
7
A U K specialist chemicals company carried out a waste review and reduced water use
by £300,000 per year and saved £400,000 on raw materials. The chemical oxygen 8
demand of its effluent was reduced by 50% with further treatment cost reductions. 9
Introduction of paint monitoring equipment to reduce the quantities of waste paint left 30
over after respraying work saved a small accident repair shop £1 2,000 per year and
reduced paint and solvent consumption by 20%. 1
3
Overlaying these questions on each area of work will help you build up a picture of
4
where to focus effort and start the review work.
5
It is worth considering the waste trail, as shown in Figure 6. 61
38
Figure 6: The waste trail

BU Y PRO DU C E S E LL
C REATE C RE ATE C RE ATE
C RE ATE C OLLE C T S TORE TRAN SP ORT DI SP O SE
Table 3: Scoring areas of

Area of a cti vi ty I n trod u ctory q u esti on s Ra n ki n g
business activity
1 l ow – 5 h i g h
Packaging & raw materials How much do we spend on raw material?

What percentage of turnover is this?
Is this too high? (If yes, rank high)
Product & process How much down time do we suffer?

What was originally planned?
(If actual down time is much higher than
planned then give a high rank)
Site management Are there any site problems that have led
to waste production?
Utilities How much do we spend on utilities?

Where is the high spend, and why?
Emission & discharges Do we measure all emissions or just those

associated with legal requirements?
Have we had any compliance or community
problems?
Paper How much paper do we use (spend and

volume)?
Where is it used?
People Do we have operating procedures?

When were they last reviewed or updated?
Do procedures cover waste minimization
techniques?
Transport & distribution What do we operate – systems and vehicles?

How do we operate?
Do we maximize efficiency?
39
Consider potential causes of waste in your organization. Note down each area that may 1
apply. 2
3
Source How it could contribute Note for action 4
Yes/No/Perhaps
5
BUY 6
Design and Does design take account of waste
specification minimization opportunities? 7
Raw materials Over-ordering 8

Incorrect specification
9
Services Are contract staff managed well?
10
Utilities Inefficient use of gas, electricity, water etc
People How are suppliers involved in decisions to 1
change product specification etc? 2
PRODUCE 3
Process material Re-work
End of run loss 4
Contaminated product 5
Out of specification
6
Packaging Systems to reduce packaging
Badly packaged goods 7
Reuse of packaging
8
Storage Period of storage or warehousing
Location of storage 9
Temperature of storage 20
Process efficiency Downtime leading to waste
1
Technology Poorly maintained equipment
Incompatibility of equipment 2
Is technology fully understood by operators? 3
Utilities Poor insulation
4
Recycling and reuse
People Poorly trained staff and contractors 5
Under-staffing 6
SELL 7
Availability Overestimating demand
8
Cancelled orders
Functionality Poor quality 9
Incorrect specification
30
Transport & Too frequent
distribution Under utilization 1
Poor scheduling 2
Empty return journey
3
Price Too high
Marketing Marketing highly packaged goods adds to 4
customer waste streams 5
People Any activities of sales staff leading to waste?
61
40
Step 4 – Evaluation
You will now have built up a wealth of up-to-date and accurate information that reflects
the way your business manages its waste. The next step is to put it into context in ways
that make sense for the business. You should be able to make distinctions between what
you must do, for example to comply with legal requirements, and what you will do to
improve your waste management. The basic steps are as follows.
• Whatever you do with the information, keep it simple.
• Evaluate the information in terms of people, systems, technology and your site. For
each of these consider:
o How are we actually performing?
o Is there established best practice for our business sector? What is it and how do
we measure up? Try searching the web and/or speaking to trade bodies to bench-
mark this.
o Do we meet applicable legislation and standards? Do we fall short or exceed them?
o What procedures might need revision, or even establishment?
o What do we need to do, what can we do and how much will it cost?
o Where do we need help?
• Draw key conclusions from the work, set these out concisely and talk with key
colleagues about the findings.
Step 5 – Reporting
Now draft a report on the review work. A co-produced draft with colleagues involved
in the process is one way to test the wisdom and efficacy of your assumptions, conclu-
sions and recommendations.
To develop a successful draft report, consider the following.
• Always discuss the outcomes with all who have been involved in the process.
• Summarize the findings as much as possible and append screeds of data.
• Use visual representation of the data as much as possible. Figure 6 could be adjusted
for your business.
• Having identified ‘must do’ and ‘could do’ areas, be more specific and add actions,
timescales and costs. You might consider the likely costs of inaction that could threaten
areas of business operation.
• Make sure the report is accessible and simple.
41
• The report should cover eight areas: 1
1. Summary – highlight the main messages, particularly the benefits in terms of iden- 2
tified cost savings, legal alignment and minimization of risk. 3
2. Purpose of the waste review – the ‘why’ questions underpinning the investment 4
of time and resources to realize business benefits. 5
3. Areas examined – which parts of the business were covered by the review and in 6
how much depth. 7
4. Results of the work – the detailed outcomes for each of the areas examined. This 8
section should set out specific and quantified results and is the foundation for 9
management decisions to implement an effective waste management strategy. 10
5. Key recommendations – now that you know what is actually going on in the busi- 1
ness, this section details what is now proposed to realize financial and 2
environmental benefits, including health and safety issues, so that a waste strategy 3
can be implemented. 4
6. Targets – this section should set out specific, measurable, achievable, realistic and 5
time-bound objectives and targets for identified priority areas. 6
7. Action plan – the ‘route map’ to bring the identified objectives and targets to life. 7
The last activity in this chapter provides an example waste action plan. 8
8. Programme for implementation – this final section provides the detailed directions 9
to sit alongside the ‘route map’ and includes the monitoring and measurement activ- 20
ities to ensure you keep on track. 1
• Present and circulate the draft for comment. As at the start of the process, keep senior 2
management in the loop and on board. 3
• Prepare a final report for sign off by the managing director. 4
• Organize a presentation of the work to relevant staff – these are the people you engaged 5
earlier in the waste review process. 6
7
Step 6 – Develop a waste policy
8
You have now taken stock of the waste in your business by gathering information and
9
analysing it. however, all this information is of limited use in isolation. The next step is
30
to formalize your commitment to effective waste management by drafting a waste
1
management policy statement.
2
What is a waste policy? 3
A waste policy is a natural development from the review work. Ideally it should be a 4
component of a wider environmental policy for the business. The waste policy might be 5
the first step towards this. In essence, a policy is a short written statement of intent 61
42
setting our your business position on waste management. It is similar to health and safety
or quality policy, and has three functions.
1 . It identifies key waste issues for the business.
2. It says what you will do in principle to manage your waste.
3. It sets out in broad terms your plan to monitor and improve your position.
To be effective a policy needs to be flexible and proactive.
Designing an effective policy
An effective policy should cover five key areas:
1 . Attitude
To draft an effective policy everyone in the business needs a positive attitude to waste
management. Commitment and positive action are the ‘glue’ that holds the policy
together.
2. Accuracy
The policy needs to be a milestone, not a millstone. It needs to set out your business
goals in an open, honest and realistic way.
3. Adequate resources
Resources – both human and fiscal – will be needed to bring the policy to life. The mix
and allocation will depend on the priorities that emerged from your waste review.
4. Awareness
Effective communication among staff at all levels will be needed to help people integrate
waste management thinking with their own functions in the organization. Suppliers and
customers will also need to know what new expectations you have of them.
5. Action
Waste management is a journey and not a destination. Your policy should reflect this
and indicate how you will monitor, audit and act.
The components of a policy should include the following.
• A broad statement of intent. For example: We are committed to management of our

waste streams to reduce waste and ensure compliance with or exceed legal requirements
relating to waste in our business.
43
• Statements on specific areas of waste management, for example relating to any of the 1
business areas that emerged as priorities from your waste review. For example: We 2
recognize that energy use and transport are potentially significant contributors to our 3
waste generation. Work will be carried out in 20xx to minimize waste generation from 4
these parts of our operations. 5
• A statement of expectations from third parties. For example: As part of our business 6
waste management strategy and through a process ofongoing consultation, suppliers will 7
be required to minimize packaging used in the supply of goods and services and reuse 8
packaging as much as possible. 9
• A statement indicating that management systems will be developed or, if they already 10
exist, adjusted, to implement, audit and update the waste management strategy. For 1
example: Our business will develop appropriate systems and procedures to manage the 2
significant environmental aspects ofour business and monitor progress towards the goals 3
we have set. 4
5
As you formulate your policy it is important to balance the long- and short-term issues. 6
Some changes in your waste management strategy might bring short-term gains, be rela- 7
tively cheap to implement and easy to measure. Others perhaps less so. Your policy needs 8
to reflect these variables and say what you will do and when. 9
20
On the following pages is an extract from the Open University environmental policy state-
1
ment for the procurement of printed materials. Waste management issues are highlighted.
2
3
‘Managing our waste effectively is a complex process. We need good data to ensure the deci-
4
sions we make are based on accurate information, and to be sure that what we do is making
5
a difference to our bottom line and the environment. We still have a lot to do. The next step
6
in our work will be to encourage more staff involvement in waste management initiatives, not
7
just their own office activities, but in the way they develop course materials so that ideally
8
“waste” becomes unacceptable.’
9
OU Estates Division
30
1
What to do with your waste management policy
2
• Make sure everyone who needs a copy gets a copy. If appropriate, a covering note, 3
face to face briefing for suppliers or letter of commitment from senior management 4
will emphasize that what you are doing is important and that the business is 5
committed. 61
44
Open University
Environmental Policy Statement for the Procurement of environmental policy
Printed Materials statement
When considering tenders for the supply of print and paper products, Materials
Procurement expects prospective suppliers to show evidence of an effective
environmental policy to include the following considerations:
1 . Control of the effects of raw materials procurement to ensure that print and paper
products come from environmentally and socially responsible sources.
Certification of paper products to the level of Forest Stewardship Council
(FSC) principles and criteria is a requirement.
2. Reduction of harmful emissions into the atmosphere.
3. The elimination of emissions into the supply of water or any other natural
resource.
4. Conservation of energy by more efficient use of energy and fuels and
transportation methods.
5. Reduction of waste levels to a minimum .
6. Ensuring waste materials are sorted and made available for recycling where
possible. Treatment and disposal of waste by the least objectionable option
that is practicable.
7. Use and disposal of chemicals and hazardous materials and possible
replacement by alternative products. Control of emissions of solvents and other
chemicals to drains.
8. Reduction of noise levels below statutory requirements.
9. Provision of safe, hygienic and attractive working environments having regard to
the nature of the activities undertaken.
1 0. Environmental aspects of current and future products and policies.
Source of Raw Materials
All virgin fibre is to be sourced from forests independently certified to the level of
Forest Stewardship Council (FSC) principles and criteria. A chain of custody
verification form is provided by paper suppliers to enable the tracing of the source of
the material to a named company and the identification of the particular forest where
the wood originated.
The Use of Energy
Some paper suppliers are using fossil fuels so energy usage is an important
consideration . Some mills re-use surplus energy from one part of the process to
supplement another. Many combined pulp and paper mills burn a mixture of wood and
chemical substance left over after the first bleaching process to give a source of
steam.
Recycling
There are a number of issues that concern the recycling of paper products. Some of
these involve the question of the quality of the paper and its printability, the amount of
genuine recycled content in a particular paper grade, and the amount of energy
consumed in de-inking, etc. Paper mills have traditionally ‘recycled’ mill broke and
45
1
trimmings and received printers’ and converters’ unprinted wood-free waste. The most
significant environmental benefits, however, come from recycling post consumer office 2
and domestic waste. 3
Papers containing a high recycled fibre content, sourced from post consumer 4
waste, are used whenever practicable. 5
Printing and Finishing 6
Printing companies are not generally viewed as being of a particularly high risk to the 7
environment but there are a number of important points to be considered. 8
Inks 9
There is an increasing use of raw materials from renewable sources in printing inks,
including vegetable oils, alkyds, rosin and cellulose derivatives, but there is a limit to 10
the amount that can be used. There is also a general decrease in the use of heavy 1
metals in printing inks. The use of solvents and evaporation drying is an area of
concern. This is mainly limited to heat set web offset inks that are increasingly used for 2
long run Open University publications. There is a certain amount of recycling and 3
reuse of inks on high volume printing presses. Ink containers are now generally
reusable. 4
The bio-degradability of inks and the de-inking processes used in the manufacture 5
of recycled papers are factors that need to be considered by suppliers with a good 6
environmental policy.
7
Chemicals
The amount of chemical solutions used by printers in their pre-press departments for 8
developing and fixing film, producing printing plates, etc., is diminishing. Chemicals are 9
used on the press in the form of washes, additives to the fountain solution, varnishes,
etc. In addition to the legislative requirements, it is expected that printing suppliers will 20
deal with such chemicals and wastage in a responsible manner. 1
Adhesives, Laminates, etc. 2

Printers primarily use emulsion adhesives and hot melts in the finishing processes.
Health and safety legislation covers the use of such materials in the manufacturing 3
process but also the degree of recyclability of adhesives is of interest. Adhesives 4

are generally not yet fully recyclable though much work is being carried out in this
area. 5
6
Waste
7
Printing companies generate a good deal of waste material including paper waste,
waste from the processing of graphic materials, metal plates, chemical bottles, 8
containers, packing materials, etc. How a printer manages and controls its waste 9
materials is of interest.
30
4
© The Open University 2006 5
61
46
• Put copies of the policy in staff handbooks and your annual reports.
• Raise staff awareness by building the policy into any related training and staff induc-
tion programmes.
• Let your customers, suppliers and even the local community know what you are up
to.
• Measure the impact of your policy and ensure that the messages are being received
and understood.
• Keep it up to date and let people know how the business is doing and how this is mak-
ing a positive difference to waste minimization, the environment and the bottom line.
Step 7 – Action, monitoring and follow-up

Most of the hard work is now coming to a close. At this stage you will have an accu-
rate, agreed and workable document that sets out the issues and actions for your business
to manage waste. Having established a plan, the investment needs to be actioned and
integrated into the business. By planning the waste review in Step 1 , the work will have
generated a great deal of interest among staff, customers, regulators and perhaps even
the local community. To put the waste review to work you will need to tell people about
it and clarify their role in the implementation process.
Now you will need to:
• Communicate your findings, for example through:
o staff briefings and meetings. Prepare a short, punchy report for all staff, setting
out the benefits to the business and wider environment;
o notice boards and magazines;
o the local and trade press;
o communications with suppliers, customers and contractors so they understand
what you have done and any new expectations you have of them;
o meetings with key staff who are directly involved in the implementation of the
report’s recommendations.
• Consider rewarding staff from savings made from their contribution to waste mini-
mization.
• Ensure that key staff are aware of resources available for waste minimization – for
example, training, investment schemes or written materials.
• Identify any new procedures and training needed to implement the recommendations
of the review.
47
• Set in place a programme of activity to: 1
o take action where and when it is needed, with key goals and timescales for achieving 2
targets; 3
o ensure that you strive for improvement in your waste management strategy. 4
• Monitor and follow up your waste management plan. 5
Make sure that you: 6
o keep up to date with changes in legislation and the implementation of legislation; 7
8
o set a timetable for checking progress on implementation; 9
o think about formalizing responsibility for waste management in job specifications 10
and appraisal systems; 1
o ensure that waste management and its benefits is a regular agenda item at manage- 2
ment meetings; 3
o report on progress, cost savings and new opportunities. 4
5
Activity 6
7
Use the blank table below to devise a waste action plan. The information assembled in
8
Step 3 will enable you to set targets and a timetable for each area of your business.
9
20
Waste management – an action plan
1
Area of Target When How Help Monitoring 2
business required and
evaluation 3
4
Packaging and
raw materials 5
Product and 6
process 7
Site management 8
Utilities 9
30
Emissions
1
Paper
2
People
3
Transport and 4
distribution
5
61
48
An introduction to
key waste legislation 5
Summary
Regulation is a key driver for managing waste and for improving environmental
performance. This Chapter guides you to who the regulator is in your area, how
legislation is made and the most relevant pieces of legislation that you should be
aware of.
5.1 Background – who are the regulators?

Complying with environmental and waste legislation is a major obligation for any organ-
ization. The legislation is continually evolving and the key to success for a business is to
anticipate the changes and then work to modify operational practices to stay ahead of
them. It is inevitable that, when you are reading this, things will have moved on from
when this guide was written. So, to stay ahead of the game, do contact your regulators.
Don’t believe the old myth that they will only ‘put the boot in’ – they are there to provide
help and advice and are pleased to do this for you. The Department for Environment,
Food and Rural Affairs (Defra) and all three of the UK’s national regulators have websites
that contain regular updates on waste and general environmental legislation.
Defra – Department for Environment, Food and Rural Affairs

www.defra.gov.uk
In England and Wales – The Environment Agency

www.environment-agency.gov.uk
In Scotland – The Scottish Environment Protection Agency (SEPA)

www.sepa.org.uk
In Northern Ireland – The Environment and Heritage Service

www.ehsni.gov.uk
49
The relevant regulatory agencies have other responsibilities in addition to waste manage- 1
ment. These include water quality, flood defence, and pollution prevention and control. 2
But all have ‘waste specific’ sections to deal with your queries. 3
4
Local issues are handled differently across the UK. For instance, in Scotland, England
5
and Wales, local authority environmental health departments deal with less complex
6
process emissions and nuisance, as do district councils in Northern Ireland. This will be
7
discussed further in 5.5.
8
5.2 European directives 10
2
Waste-related and general environmental pollution does not respect national boundaries,
3
so the European Union is particularly active in developing measures to protect the whole
4
of the EU. Several far-reaching measures are being implemented, many of which also
5
contribute to the EU goal of a single market. Appendix 3 lists a range of EU-driven legis-
6
lation that is due in the next few months or years.
7
The EU can issue regulations, directives and recommendations that are binding without 8
a response from the legislators of the member states. EU policies in general are the result 9
of decisions taken by three main institutions: 20
1
• the Council of the European Union (representing the member states) ;
2
• the European Parliament (representing the citizens) ;
3
• the European Commission (a politically independent body that upholds the collec-
4
tive European interest) .
5
6
However, most European legislation is implemented in the UK through the following
7
stages.
8
9
The Council meets to discuss relevant issues (if it is a waste issue, for instance, then
30
countries send their minister responsible for the environment) . The main policies are
1
decided here.
2
A directive comes from the European Commission. Every year between March and July 3
the Commission will launch consultations on topics that it wants to cover the following 4
year. So it is worth checking where official consultations are occurring (see http://europa. 5
eu.int/yourvoice/consultations/index_en.htm) to determine if anything is coming up that 61
50
5. AN I N TRO D U CTI O N TO KEY WASTE LEG I S LATI O N
affects your sector. You could also keep in contact with your MEPs during this time to
enquire about forthcoming consultations.
At this point the Commission’s proposals are out for consultation and hence open for
feedback. At the end of the year the Commission reviews the feedback on its proposals,
and each proposal is either rejected or formally adopted. This changes its status from a
white paper to an official proposal, and the legislation procedure starts from here. It can
be accepted either without amendment or amended at this stage.
The European Parliament consists of the MEPs voted for by each member country.
Parliament and Council share legislative power. Parliament gives its opinion on draft
directives and regulations proposed by the European Commission, which can then be
amended to reflect Parliament’s input. Parliament is on an equal footing with the council
when legislating on important issues such as the environment, and has the power to
throw out legislation if the majority of MEPs vote against the Council’s ‘common posi-
tion’. However, the matter can then be put to a ‘conciliation committee’.
The UK parliament then implements the directive through either an Act of Parliament
or one or more regulations.
A good example of this is the waste hierarchy. In 1 989 a Community Strategy for waste
management was approved within the EC, establishing a hierarchy of priorities. This was
confirmed in 1 996 (Commission of the European Communities, 1 996) . The principles
of this hierarchy are now present in UK waste law. The hierarchy of priorities is shown
in Figure 7. This hierarchy underpins the principles behind current European directives.
U K national waste strategies
This section begins by looking at the UK’s national waste strategies. Although most of
the provisions of these strategies relate to household and municipal wastes, they will
have important implications for businesses. This section will consider three significant
developments in waste management.
Duty of care affects all producers of commercial and industrial waste, regardless of the
amount or composition of the waste. This subject was introduced in Chapter 3 but, given
that your business will be covered by the regulations, they deserve some repetition.
51
Figure 7: Waste hierarchy 1
2
Reduction
3
Reuse 7
Recovery 10
recycling
composting 1
energy
2
4
Disposal
5
7
The Landfill Directive is currently being implemented throughout the EU and is designed
8
to reduce the risk of water and air pollution from the landfilling of waste. This is to be
9
achieved by increasing the standards of landfills and limiting the amount of biodegrad-
20
able municipal waste that can be landfilled. As far as businesses are concerned, it will
1
have the following impacts.
2
• There will be financial and other pressures from local authorities on businesses whose
3
4
waste forms part of the municipal waste stream (ie waste collected by or on behalf
5
of the local authority) . Don’t forget that paper is classed as biodegradable so, if the
6
council collects your waste, you will be affected by this. Expect to see increases in
7
your disposal fees and a ‘carrot and stick’ approach to encourage you to segregate
8
more paper and other recyclable materials for recycling or composting.
• The number of landfill sites that can accept hazardous waste has been reduced to
9
30
fewer than 1 0 sites in the UK. So, if you produce hazardous waste, expect the disposal
1
charges to rise. You may also find it harder to find a contractor who will accept your
2
hazardous waste.
3
Producer Responsibility is based on the concept that the suppliers of a material that 4
becomes waste have a responsibility to ensure that the material is disposed of in the most 5
environmentally benign way at the end of the product’s life. Producer responsibility was 61
52
introduced for packaging waste in 1 997, and packaging manufacturers, goods manufac-
turers who use packaging and retailers have a joint responsibility for recycling specific
percentages of each main packaging material. Producer responsibility is currently being
extended to cover electrical and electronic goods and end-of-life vehicles. Companies
should expect this to be expanded to cover other waste in the future.
Relevant UK waste legislation

Companies should also be aware of the following legislation, although they are not
covered in detail here:
• Environment Act 1 995 – the origin of waste strategies in the UK.
• Controlled Waste Regulations (1 992) – most businesses will be affected by these, as
controlled waste includes household, industrial and commercial waste. Much of the
legislation for household waste also applies to business waste.
• There is also a lot of legislation on licensing and landfills that may not be particu-
larly relevant to your company, such as the Waste Management Licensing Regulations,
(1 994, amended 1 995, 1 996, 1 997) , and the Waste Management Regulations 1 996 etc.
However, this drives how a waste management contractor has to deal with the waste
your company might produce.
5.3 Waste strategies

The governing bodies of the UK have produced waste strategies that present broad
outlines of how they intend to manage all types of waste. The main points of each strategy
are set out below.
Most of the targets set by the strategies cover household or municipal waste. If your
waste is collected under a local authority scheme it is classed as ‘municipal waste’, so you
will be affected by these targets, although your business is unlikely to be required to
actively take part unless requested to do so by your local authority. Even if your waste
is not classed as ‘municipal’, the strategies present a clear idea of the way thinking is
developing in waste management regulation.
England
Waste Strategy 2000 was published in spring 2000 and is currently (autumn 2006) being
reviewed. The aim of the strategy is to adopt a more sustainable way of dealing with our
waste. The foreword to the strategy explains that ‘sustainable’ means:
53
‘. . . designing products which use fewer materials and using processes that produce less waste. 1
It means putting waste to good use, through reusing items, recycling, composting and using 2
waste as a fuel. And it means choosing products made from waste materials.’ 3
4
This certainly echoes many of the ideas discussed in Chapters 3 and 5.
5
6
The strategy also sets the targets shown in Table 4.
7
8
Table 4: English waste
management targets By 2005 to reduce the amount of industrial and commercial waste sent to landfill to 9
85% of the amount landfilled in 1 998.
10
To recover (materials, compost and energy) value from 40% of municipal waste by
1
2005, 45% by 201 0 and 67% by 201 5.
2
To recycle or compost at least 25% of household waste by 2005, 30% by 201 0 and
33% by 201 5. 3
At the time of going to press it was not clear that these targets would be met, although 6
an overall fall in waste generated of 1 % and improved recycling figures were reported 7
in 2003/2004 by Defra. 8
9
In order to try and meet recycling targets, the Waste & Resources Action Programme
20
( WRAP) was established in 2001 in response to the UK Government’s Waste Strategy
1
2000 to promote sustainable waste management. WRAP was initially set up to create
2
stable and efficient markets for recycled materials and products for the 1 00 million tonnes
3
of waste accounted for by commercial, industrial and municipal waste (this includes
4
waste from houses, offices and factories) . Various materials were targeted, including aggre-
5
gates, glass, organics, paper, plastics and wood, supported by work in three generic areas:
6
financial mechanisms, procurement and standards. More recently WRAP was also tasked
7
with reducing waste at home (eg composting) , advising local authorities on recycling
8
and improving public awareness of recycling.
9
30
Wales
1
Waste Strategy 2000 originally applied to both England and Wales, but in 2002 the 2
Government of the National Assembly for Wales produced its own strategy, ‘Wise About 3
Waste’. This strategy sets more challenging targets for recycling and composting of muni- 4
cipal waste, as shown in Table 5. 5
61
54
Year Minimum Minimum Minimum Welsh waste

Table 5:
composting recycling combined management targets
rate (%) rate (%) composting and
recycling rate (%)
2003/04 5 5 15
2006/07 10 10 25
2009/1 0 15 15 40
Scotland
In 1 999 SEPA produced the Scottish Waste Strategy, based on three key principles:
1 Those responsible for managing wastes (mainly businesses and local authorities)
should apply the principle of Best Practicable Environmental Option (BPEO) to ensure
that waste is managed in a way that provides the greatest environmental benefit (or
causes the least amount of environmental damage) taking account of the total envi-
ronment (land, water and air) .
2 The Waste Hierarchy should be used as a basis for determining BPEO. In the hier-
archy, shown in Figure 7, the further up the hierarchy, the better the option.
3 The Proximity Principle states that waste should be managed as close to the point of
production as possible. This prevents the export of problems to other regions and
countries and also recognizes that transporting waste can have a significant environ-
mental impact.
Eleven Regional Waste Strategy Areas were then set up and each one was required to
produce a regional waste plan based on the three principles. The 1 1 plans all set targets
for recycling, composting and energy recovery from municipal waste for the years 201 0
and 2020. These plans then combined to produce the National Waste Plan which sets
the overall targets shown in Table 6.
Short-term targets for local authorities: Scottish waste

Table 6:
management targets
• increase recycling and composting to 25% by 2006;
• reduce biodegradable wastes sent to landfill to 1 .5 million tonnes by 2006.
Longer-term targets:
• stop the growth in municipal waste by 201 0;
• achieve 35% recycling and 20% composting of municipal waste by 2020;
• provide 90% of households with kerbside recycling facilities by 2020;
• recover energy from 1 4% of municipal waste;
• reduce landfilling to 30% of municipal waste.
55
Northern Ireland 1
2
The Northern Ireland Waste Strategy was published in March 2000 following a three-
3
year consultation exercise. It sets a number of targets relating to household and municipal
4
waste. These targets, shown in Table 7, incorporate the requirements of the Landfill
5
Directive and also include a specific target to reduce household waste generation.
6
7
Table 7: Northern Ireland
waste management targets To recover materials or energy from 25% of household waste by 2005 and 40% by 8
201 0.
9
To recycle 1 5% of household waste by 2005 and 40% by 201 0.
10
To reduce the landfilling of biodegradable municipal waste to 75% of the 1 995 level
1
by 201 0, 50% by 201 3 and 35% by 2020.
2
To reduce household waste generation to the 1 998 level by 2005 and then reduce it
by 1 % every three years. 3
6
5.4 The Landfill Directive 7
8
The Landfill Directive is (1 999) intended to change the way in which waste is dealt with
9
within the EU – and force it up the waste management hierarchy, rather than relying
20
mostly on landfilling as has been the case in the past.
1
2
The Directive’s overall aim is ‘to prevent or reduce as far as possible negative effects on
3
the environment, in particular the pollution of surface water, groundwater, soil and air,
4
and on the global environment, including the greenhouse effect, as well as any resulting
5
risk to human health, from the landfilling of waste, during the whole lifecycle of the
6
landfill’. It also lays out technical specifications for the operation of landfills in terms of
7
environmental emissions and sets targets for the reduction of biodegradable components
8
to be landfilled. To meet this in the UK a Landfill Allowance Trading Scheme (LATS)
9
has been initiated.
30
It also bans other types of waste from landfill, including liquids, clinical waste, tyres and 1
any other waste that in the conditions of landfill is explosive, oxidizing, corrosive, flam- 2
mable or highly flammable, or ‘any other waste that does not fulfil the acceptance criteria’. 3
Further information on LATS and the waste acceptance criteria can be found at 4
www.defra.gov.uk, or obtained from the regulators in England, Scotland and Northern 5
Ireland. 61
56
5.5 The Environmental Protection Act and Duty

of Care
In England, our law is a mix of UK and European driven legislation. Before the intro-
duction of modern waste regulation under Part II of the Environmental Protection Act
(EPA) 1 990, the deposit or disposal of waste in the UK was regulated through waste
disposal licences under the Control of Pollution Act 1 974. Part II of the EPA introduced
a more comprehensive scheme of waste management licensing that required applicants
to prove their competence, both financial and technical, to hold a waste management
licence.
The EPA also introduced the statutory duty of care, provided for the outsourcing of local
authority waste management functions to local authority waste disposal companies
(LAWDCs) , and introduced detailed regulatory provisions in relation to the collection,
disposal and treatment of controlled waste.
The EPA is still the main source of regulatory powers, although it has been supplemented
by changes introduced by the Environment Act 1 995 and more latterly the Pollution
Prevention and Control Act 1 999 (among others) .
Section 33 of the EPA states that:
‘a person shall not –
(a) deposit controlled waste, or knowingly cause or knowingly permit controlled waste to
be deposited in or on any land unless a waste management licence authorizing the
deposit is in force and the deposit is in accordance with the licence;
(b) treat, keep or dispose of controlled waste, or knowingly cause or knowingly permit
controlled waste to be treated, kept or disposed of –
(i) in or on any land, or
(ii) by means of any mobile plant,
except under and in accordance with a waste management licence;
(c) treat, keep or dispose of controlled waste in a manner likely to cause pollution of the
environment or harm to human health.’
It is worth explaining that:
• the word ‘person’ is used in a legal sense and means either a human or a company;
• ‘controlled wastes’ include commercial and industrial waste (with a few exceptions) ;
57
• ‘knowingly cause or permit’ means that your firm will be liable if your contractor 1
breaks these laws, although it is an acceptable defence to prove that you took ‘all 2
reasonable precautions and exercised all due diligence to avoid the commission of the 3
offence’. 4
5
The section goes on to say that: 6
7
‘a person who commits an offence under this section shall be liable –
8
(a) on summary conviction, to imprisonment for a term not exceeding six months or a
9
fine not exceeding £20,000 or both; and
10
(b) on conviction on indictment, to imprisonment for a term not exceeding two years or
1
a fine or both.
2
3
(9) A person who commits an offence under this section in relation to special waste shall be
4
liable –
5
(a) on summary conviction, to imprisonment for a term not exceeding six months or a
6
fine not exceeding £20,000 or both;
7
(b) on conviction on indictment, to imprisonment for a term not exceeding five years or
8
a fine or both.’
9
Note that ‘Special Waste’ is now known as ‘hazardous waste’ and is discussed in 5.7. 20
1
Section 34 of the act then goes on to define the duty of care that all waste producers 2
have to: 3
4
• prevent contravention of Section 33 of the act;
5
• prevent the escape of any waste;
6
• ensure that waste is only transferred to ‘appropriate persons’;
7
• make sure that any transfers are accompanied by a description of the waste.
8
9
Defra has published a code of practice that gives a step-by-step guide to complying with
30
duty of care. If you have any doubts about how your waste is managed you should consult
1
this guide. In summary, the guide explains how you must:
2
• identify and describe your waste; 3
• store the waste in a safe and secure manner; 4
• transfer the waste to the correct organization(s) ; 5
• check that the transfers and final disposal have been carried out in the correct manner. 61
58
Statutory nuisance
Part III of the EPA 1 990 contains the main legislation relating to statutory nuisance. It
applies in England, Wales and Scotland and is enforced by the local authorities. The
Public Health (Ireland) Act 1 878 contains the main legislation relating to statutory
nuisances in Northern Ireland. Under Part III of The Pollution Control and Local
Government (Northern Ireland) Order 1 978, district councils have powers to deal with
noise nuisance.
Although there is no legal definition of a statutory nuisance for action to be taken, the
nuisance complained of must be, or be likely to be prejudicial to people’s health or inter-
fere with a person’s legitimate use and enjoyment of land. This particularly applies to
nuisance to neighbours in their homes and gardens. This is why a local authority
Environmental Health Officer (EHO) tends to enforce issues to do with nuisance.
A statutory nuisance could arise from the poor state of your premises or any noise,
smoke, fumes, gases, dust, steam, smell, effluvia, the keeping of animals, deposits and
accumulations of waste and/or other material, and other escapes from your premises. If
your premises are found to cause a nuisance the EHO can issue an abatement notice
requiring your company to stop the nuisance or carry out works to prevent it.
Many nuisances from businesses tend either to be noise from traffic or production, or
from odours or dust. Obviously the way in which you deal with your waste may be an
important potential source of nuisance; hence you must take into account your neigh-
bours before embarking on any large-scale storage or change in disposal or recycling of
materials. This could also include regularly checking your site for any waste, accumula-
tions, evidence of vermin, noise or smell as applicable.
The advice given by Netregs (www.netregs.gov.uk) is that if your business is regulated
under PPC, IPC, LAPC or LAPPC, your authorization or permit may have conditions
that relate to some emissions that could be a statutory nuisance. Enforcement action will
usually be taken under those regimes for most types of statutory nuisance. However,
your business could still face statutory nuisance action under Part III of the EPA 1 990,
Pollution Control and Local Government (NI) Order 1 978 or Public Health (Ireland)
Act 1 878 where the nuisance is not covered by a condition of the authorization or
permit.
59
5.6 Packaging waste 1
The EC Directive on Packaging and Packaging Waste 94/62/EC seeks to reduce the impact 3
of packaging and packaging waste on the environment, by introducing recovery and 4
recycling targets for packaging waste, and by encouraging minimization and reuse of 5
packaging. 6
7
The Producer Responsibility Obligations (Packaging Waste) Regulations 1 997 (as
8
amended) are intended to encourage the minimization of packaging and packaging waste,
9
incentivize reuse and increase the recovery and recycling of packaging waste. The amount
10
of packaging waste producers have to recover and recycle is determined, in part, by the
1
amount of packaging they handle.
2
3
The regulations place obligations on certain businesses that satisfy two threshold tests
4
to recover and recycle specified tonnages of packaging waste each year. Businesses with
5
producer responsibility obligations are those that:
6
• handle more than 50 tonnes of packaging; 7
• have more than £2 million financial turnover. 8
The amount each business has to recover is determined by three factors: 20
1
• the amount of packaging the business handles;
2
• the business recovery and recycling targets for the year;
3
• the activity the business carries out on packaging.
4
5
Each year UK businesses face recovery and recycling targets designed to enable the them
6
to meet the recovery and recycling targets in the Packaging and Packaging Waste Directive
7
by 31 December 2008 as required. The UK has ‘business’ targets that are set to meet the
8
national targets. These are different because a number of smaller businesses are excluded
9
from the obligations, and those that are obligated have to share the obligation between
30
them. Thus, as currently published, there is a business recovery target of 70% in 2008
1
to meet the directive target of overall recovery of 60%. Individual materials have indi-
2
vidual targets within this overall total.
3
If your company has any obligations under the packaging waste regulations it may need 4
to join a compliance scheme. You can find details of these at http://www.defra.gov.uk/ 5
environment/waste/topics/packaging/ which also gives advice on various legislation. 61
60
5.7 Hazardous waste

European Council Directive 91 /689/EEC (the Hazardous Waste Directive) sets the frame-
work within member states of the European Community for provisions to control the
movement of arisings of hazardous wastes. The Hazardous Waste (England and Wales)
Regulations 2005 came into effect on 1 6 July 2005. The full text of the regulations can
be found at http://www.opsi.gov.uk/si/si2005/20050894.htm
In Scotland the Landfill (Scotland) Regulations 2003 refer to hazardous waste and define
it by reference to the Hazardous Waste Directive, alongside the Special Waste Amendment
(Scotland) Regulations 2004, which fully implement the European Waste Catalogue. The
Hazardous Waste Regulations (Northern Ireland) 2005 (SR 2005/300) and the List of
Waste Regulations (Northern Ireland) 2005 (SR 2005/301 ) came into force on 1 6 July
2005 and revoked the Special Waste Regulations (Northern Ireland) 1 998 (SR 1 998/289) .
These new regulations were introduced to implement the provisions of EC Directive
91 /689/EEC as amended and Commission Decision 2000/532/EC.
What is hazardous waste?
‘Hazardous waste’ is a broad term and covers a wide range of materials. The classifica-
tion of some wastes as hazardous (such as strong acids, mercury or asbestos) is obvious.
These substances cause immediate serious harm to humans, are toxic or cause cancer.
For other materials that cause a longer-term threat to the environment, the need for
hazardous classification is less apparent, for example cathode ray tubes from televisions
and computer monitors, and even refrigerators.
Many everyday substances and objects are now classed as hazardous when they become
waste. For example, fluorescent light tubes, fridges, televisions and vehicles.
You can find out if any of your wastes are hazardous by reference to the European Waste
Catalogue (implemented in England under the List of Wastes Regulations (2005) and in
Scotland and Northern Ireland in the above mentioned legislation) . This is a compre-
hensive list of wastes identified by a numerical code; those that are classed as hazardous
are indicated by a star. Some wastes are classed as hazardous whatever their composi-
tion. For example:
03 02 04* inorganic wood preservatives.
61
Other wastes are possibly hazardous depending on their composition. For example: 1
2
03 20 05* other wood preservatives containing dangerous substances.
3
4
To determine whether such a waste is hazardous or not, two points must be established.
5
6
a) Does the waste contain dangerous substances? If it does,
7
b) Does the waste have any of 1 4 listed hazardous properties (explosive, oxidizing, flam-
8
mable, toxic, carcinogenic, irritant, harmful, corrosive, infectious, mutagenic, terato-
9
genic, ecotoxic, substances and preparations which release toxic or very toxic gases and
10
finally substances and preparations capable by any means, after disposal, of yielding
1
another substance) .
2
As an example, refrigerators fall under the terms of these regulations as they are deemed 3
‘H1 4 – Ecotoxic: substances and preparations which present or may present immediate 4
or delayed risks for one or more sectors of the environment’. This is due to the presence 5
of CFCs in older equipment, which are responsible for the depletion of the stratospheric 6
ozone layer. More modern fridges and freezers use HCFCs in place of CFCs, but are still 7
classed as hazardous because they are still ecotoxic (as they still have the potential to be 8
either ozone damaging or potentially contribute to global warming) . In the case of 9
pentane, another often used material for refrigerators, it is highly flammable. 20
1
Answering these questions requires specialist knowledge and you should consult an
2
appropriate expert if you think that any waste you produce is hazardous. The three UK
3
national regulators have published guidance for companies and you should consult them
4
for further information.
5
6
H ow sh ou l d I d eal wi th h a za rd ou s waste?
7
The regulations governing hazardous waste management were introduced on 1 5 July 8
2005. To repeat the advice given at the beginning of the Chapter: 9
30
if you think you are producing hazardous waste – consult your national regulator.
1
2
Once you know that you are a hazardous waste producer in England and Wales you must
3
register at the Environment Agency (http://www.environment-agency.gov.uk/subjects/
4
waste/1 01 9330/1 029396/) as a producer. There are exceptions to this need for premises
5
producing less than 200 kg a year of hazardous waste, including offices, shops, farms,
61
62
dental, veterinary and medical practices. Premises in Scotland or Northern Ireland do
not have register as producers for these regulations, even if they export their waste to
England or Wales. In Scotland, however, there are consignment notes issued by SEPA,
and in Northern Ireland regulations also require consignment and extensive records.
When hazardous waste has to be collected from registered premises, a consignment note
system must be used. The producer completes the parts of the form that give a detailed
description of the waste and signs to the effect that it has been collected by the carrier.
The carrier signs that they have accepted the waste. The final waste management facility
completes the last part of the form to confirm that the waste has been accepted and
indicates whether it was subject to a disposal or recovery operation. Completed copies
of the forms are to be retained by all concerned (and must be produced to the relevant
agency or emergency services on request), and the final disposal operator must make
quarterly returns to the Environment Agency giving details of all consignments received
(as must the carrier if they are different to the disposal operator) .
Several classes of electrical and electronic equipment are now classed as hazardous waste.
At the moment, any waste of this nature that you need to dispose of must be treated in
the same way as any other hazardous waste. However, once the Waste Electrical and
Electronic Goods ( WEEE) Directive is implemented, there will be changes to this system.
Note that under the hazardous waste regulations you must register as a producer and
you must consign your waste. Failure to do so could result in prosecution. However,
there are also other aspects to consider. The regulations specifically cover the mixing of
different categories of hazardous waste – you will need to check the different categories
of waste to see what is deemed as hazardous, as this will affect your storage arrange-
ments.
5.8 WEEE Directive

The Waste Electrical and Electronic Equipment ( WEEE) Directive aims to improve the
way the UK manages WEEE while protecting human health and the environment. It
sets targets for collecting WEEE, new standards for the treatment of WEEE, and strict
recycling and recovery targets to help minimize its disposal. There have been delays in
implementing the directive in the UK and some other member states and it is now due
to be implemented in the UK sometime in 2007.
63
The directive requires member states to achieve specified recycling rates for WEEE (the 1
UK has already met the 2006 target of 4 kg per household per year) , and for the industry 2
to establish a producer responsibility scheme to collect and recycle WEEE. 3
4
As far as WEEE produced by businesses is concerned, distributors of new equipment
5
will be required to collect the old equipment being replaced on a ‘one-for-one basis’. For
6
example, a firm supplying an office with 1 0 new personal computers will be required to
7
collect 1 0 old PCs for processing. This leaves the question of so-called ‘orphan’ equip-
8
ment and it is unclear what the situation will be for a firm that wishes to scrap (say) an
9
old computer monitor without replacing it.
10
2
If your business is involved in the manufacture, selling, distribution, recycling or
treatment of electrical or electronic equipment or components, then the WEEE 3
Regulations will apply to you. The WEEE Regulations cover 1 0 categories of
4
equipment:
• large household appliances, such as refrigerators and cookers; 5
• small household appliances, such as vacuum cleaners and coffee makers; 6
• IT and telecommunications equipment, such as computers and fax machines; 7
• consumer equipment, such as televisions and hi-fis; 8
• lighting equipment, such as bulbs and fixtures; 9
• electrical and electronic tools, such as drills and sewing machines; 20
• toys, leisure and sports equipment, such as video games and slot machines; 1
• medical devices, such as laboratory equipment and dialysis machines; 2
• monitoring and control instruments, such as smoke detectors and thermostats; and 3
• automatic dispensers, such as cash machines and drinks dispensers. 4
5
The WEEE Regulations do not cover:
• equipment not powered directly by electric currents or electromagnetic fields, for 6
example pneumatic tools, combustion engines or petrol-driven lawn mowers; 7
• products with electronic or electrical components that are not needed to perform 8
their primary function, such as musical greetings cards;
9
• electrical or electronic equipment that is an integral part of another type of
30
equipment such as a car radio;
• large-scale stationary industrial tools; 1
• medical implants or infected medical equipment at the end of its life; 2
• household luminaires; 3
• filament light bulbs; or 4
• equipment used by the military or security services. 5
61
64
It is important to note these regulations will apply retrospectively, so any products you
have had an involvement with in the past will need to be considered. If you are a busi-
ness user responsible for the equipment, then you will need to report evidence of its
collection, treatment and recovery according to the recovery and recycling or reuse targets.
If you have produced or supplied items classified as WEEE, or you are a retailer or distrib-
utor of electrical and electronic equipment, then further requirements are applicable, for
example you may need to register and establish a take-back scheme. Check this with
your local regulator.
5.9 End-of-life vehicles

The End-of-Life Vehicles (ELV) Directive aims to reduce the environmental impact of
scrap vehicles and increase the recovery of materials from these vehicles. Under the terms
of the directive, the vehicle producers must meet the costs of treating ELVs for recovery
and disposal from 2007. Until this time, the last registered owner of a vehicle is respon-
sible for its disposal and for meeting any costs incurred.
The motor industry is setting up a network of organizations to collect and reprocess
ELVs. The full text of the regulations can be seen at http://www.opsi.gov.uk/si/si2003/
20032635.htm. Car manufacturers in England and Wales are also subject to the End of
Life Vehicles (Producer Responsibility) Regulations 2005, which can be seen at
http://www.opsi.gov.uk/si/si2005/20050263.htm.
Between now and 2007, your business must dispose of an ELV through an Authorized
Treatment Facility. They will take the vehicle and issue you with a Certificate of
Destruction. Without such a certificate, as far as the DVLA is concerned, the vehicle is
still in existence and you will be liable for road tax. There are around 1 ,000 treatment
facilities in England and Wales, and a list of them is available on the Environment Agency’s
website. Hence even if you get a local scrap merchant to clear a vehicle for you, make
sure they are a registered treatment facility and can supply you with the correct paper-
work.
Different regulations exist for disposal of polychlorinated biphenyls (PCBs) , polychlorin-
ated terphenyls (PCTs) and oils. If your company produces any of these substances you
are advised to ensure your waste is both correctly consigned and meets the relevant
legislation.
65
1
10
20
30
61
Waste management in relation
to other management systems 6
Summary
In earlier chapters we described the drivers for waste management, including the
‘must do’ demands of waste legislation. By now we hope you have started to consider
the ways in which effective waste management adds up to measurable business
advantage. Money saved off the bottom line has added value if you factor in that
to make the same profit would require 1 0 or even 1 5 times more sales.
In this chapter we consider the relationships that waste management activities need
to have with other management systems that may be in place. For example, there
are explicit links between aspects of waste management and health and safety. These
might include risk assessments associated with the use of toxic substances, which
need to consider operator health and safety issues, relevant legislation, potential
environmental impacts and the most cost-effective way of maintaining production.
A metal fabrications company switched from organic solvent-based degreasing

to a detergent-based system. This reduced operator exposure to solvents,
maintained compliance with regulator discharge consents, significantly reduced
its waste burden and environmental impact, and saved it over £1 4,000 per year
on waste disposal charges.
The case we make in this chapter is that to be effective, waste management activity
needs to consider and link with any other management systems that the organiza-
tion has in place. At a shop floor level, it needs to complement and not conflict
with procedures that are in place. We have argued in earlier chapters that waste
management needs to be taken seriously and be seen to be taken seriously. Good
intentions need to become good practice. However well implemented, waste manage-
ment as a standalone business activity will never realize its full potential to deliver
measurable business benefit and competitive advantage. In this chapter we look at
the main management systems that may be in place in the organization – i.e. quality;
environmental; health and safety; and sustainability, and consider the common
ground they share.
67
1
6 .1 I n trod u cti on
In a medium-sized or large organization, duplication of effort in terms of policy, prac- 3
tice and people may already occur with associated potential conflicts at an operational 4
level. In a smaller organization there is unlikely to be the luxury of duplication of effort, 5
especially if one person has responsibility for everything. In practice here, the focus is 6
likely to be on areas of greatest short-term need, for example in response to the hot 7
breath of the regulator on one’s neck! This imposed myopia can mean missed opportu- 8
nity. In both these scenarios it is almost certain that an integrated approach will bring 9
greatest benefit. To bring these points to life we have included a case study example and 10
final short exercise to help you consider the pros and cons of integration. Suggested solu- 1
tions can be found in Appendix 4. 2
A waste and environmental review by a London based timber treatment company 4

revealed significant opportunities to reduce the toxicity of the chemicals it used. This
5
led to improved health and safety of staff, reduced costs, including waste disposal,
and a 40-fold decrease in the toxicity of treatment chemicals. This led to measurable 6
competitive advantage and several new contracts were secured with customers
7
looking to improve their own environmental performance by choosing subcontractors
committed to reducing pollution. 8
20
1
6 .2 Wh y i n teg rate wa ste m a n a g em en t wi th oth er
2
m an a g em en t system s?
3
4
There are five key drivers that justify an integrated management approach.
5
1 . Leg i sl ati on com pl i an ce ben efi ts 6
7
There is no choice here. Ignoring waste and environmental legislation will eventually
8
lead to prosecution, fines and ultimately could lead to imprisonment. For example this
9
is equally true for health & safety management, which must address both the 1 972 Health
30
and Safety at Work Act and the 1 992 Management of Health and Safety at Work
1
Regulations. The legislative links with quality management are a little less concrete,
2
but do apply to product fitness for purpose and health & safety links associated with
3
product use.
4
The bottom line is that employers have a responsibility to protect their staff from any 5
risks associated with their operations. 61
68
6. WASTE M AN AG E M E N T I N RE LATI O N TO OTH E R M AN AG E M E N T SYSTE M S
2 . Fi n a n ci al ben efi ts
Integration means reduced administration costs, simplified documentation and reduced
internal and external audit activity, all adding up to cost savings.
Any waste, environmental, health and safety, quality or Corporate Social Responsibility
(CSR) incidents will affect the bottom line. Fines for breaches of legislation are one
obvious example of a fiscal concern.
3. O pera ti on a l ben efi ts
These emerge through continuity and consistency of working practices, crossover of best
practice across all areas, and less disruption in implementation and operation of manage-
ment systems.
4. M an ag em en t ben efi ts
Through decreased senior management time inputs needed and reduced or no need for
separate operations for each area of management.
5. Stra teg i c ben efi ts
Including improved logistics, better stakeholder relationships and improved internal
communication through a team approach.
6 .3 I n teg rati on
In all management systems, no matter what the object of management, there are enough
similar drivers, mechanisms and requirements to suggest that a common approach makes
the best sense in terms of resource utilization. By integrating the management systems,
the business benefits can be multiplied and an organization can respond to change, so
anticipating or moving beyond any targets, for example changes in legal requirements,
well before they are externally imposed.
A useful starting point in developing an integrated system is to investigate common ground
shared between systems, as illustrated in Table 8. The ISO 9000 series gradually become
increasingly customer-oriented over time and now places greater emphasis on setting mea-
surable objectives and targets, and on measuring product and process performance. In short
it follows a systemic approach to management. Approaches to developing a health and
safety management system use similar models and even the development of sustainability
management models bear evidence of the same Deming6 ‘Plan/Do/Check/Act’ lineage.
69
Most organizations have established systems to deal with health & safety and quality 1
management. Some have established or are building environmental management systems. 2
In all three systems there is much common ground, which suggests a common approach 3
may make best sense in terms of resource utilization. 4
5
A useful starting point in developing an integrated system is to investigate common
6
ground shared between the systems, as illustrated in Figure 8.
7
Figure 8: The Natural Step
Funnel
8
Resources
© The Natural Step Through innovation 9
Life supporting
Funnel, reproduced with resources are decreasing.... creativity and the unlimited
permission from The potential for change 10
....demand for
Natural Step International resources is increasing we can open the
1
walls of the funnel
(www.thenaturalstep.com) Demand
2
4
Quality management systems have developed steadily as a business since the
publication of the BS 5750, Quality Management Systems, in 1 982. Now superseded 5
by the international standard series, ISO 9000, the vocabulary of quality has become
6
an accepted part of day-to-day management. Quality management standards indicate
best practice as defined by international experts in the field and can be used to 7
provide assurance of an organization’s ability to meet defined objectives. Closely linked
8
to quality management and the standards that define it, is the concept of ‘total quality
management’ or TQM. TQM is a change mechanism that is targeted at developing a 9
customer-driven organization through integrative working practices. The underlying
20
purpose of TQM has much common ground with an environmental management
system, although the modes of delivery are often quite different. 1
Environmental management systems (EMS) share some common ancestry with 2

quality management systems and like them are voluntary standards. Indeed, the 3
original environmental management systems standard, BS 7750 7 , was originally
proposed as an annex to BS 5750. It rapidly took on a life of its own and now has 4
three manifestations: 5
I SO 1 4001 (2004 superseding the 1 996 version), Environmental Management 6

Systems – Specification with Guidance for Use. 7
EMAS I I (2001 superseding the 1 993 version), the European Union’s eco-management 8
and audit scheme. EMAS II requires organizations to implement an EMS that meets the 9
requirements of ISO 1 4001 , the first step to convergence of standards. In addition,
EMAS requires an initial environmental review and a published environmental statement. 30
Both need to be externally verified. 1
3
6 The Deming cycle, or PDCA cycle is a continuous quality improvement of four repetitive steps – Plan, Do,
Check (or Study) and Act. The origin of the PDCA cycle can be traced back to the statistician Edward W. 4
Deming and is a modification of Walter A. Shewart’s work on statistical process control in the 1 920s.
5
7 Developed by BSI and published in 1 994, BS 7750 was the world’s first environmental management systems
standard. 61
70
BS 8555 (2003) is the new kid on the block and sets out a phased implementation of
EMS 8. Aimed primarily at small and medium-sized enterprises, it provides a staged
route to ISO 1 4001 and/or EMAS, but has some extra requirements mainly
concerning the use of performance indicators.
Health and safety management is essentially a set of external controls dictated to
business and which are achieved by establishing and fulfilling specific targets. Often,
the law requires an organization employing more than five people to have a well-
defined health and safety policy and a trained and proficient member of staff to
implement health and safety, and to carry out the necessary risk assessments of
operations and then develop related control activities. Organizations that effectively
manage health and safety exhibit some common characteristics. They have their
health and safety risks under control and strive towards continual improvement in
their health and safety record. Again, there are several echoes of environmental
management, but more at an operational than strategic level.
Sustainability is a simple concept relating to the capacity of a system – for example
Earth – to renew itself through interlinked ecological systems powered by captured
sunlight energy. Linked to and distinct from sustainability came sustainable
development (SD) 9. The key difference is that sustainable development is a process
not a condition. Literally hundreds of definitions of sustainable development exist, most
rooted in Gro Harlem Bruntland’s 1 987 speech at Our Common Future, The World
Commission on Environment. Here, the former Prime Minister of Norway said:
‘Humanity has the ability to make development sustainable – to ensure that it meets
the needs of the present without compromising the ability of future generations to
meet their own needs.’ Or, as John Gummer, then U K Environment Minister put it: ‘Not
cheating on our children’. In a survey (European Chemical News, June 1 999) of almost
500 senior business executives, 94% said that sustainable development was
important for business. Moreover 82% believed companies derived real business value
from sustainable development.
Sustainable development can be summarized by four straightforward concepts:
1. Nothing comes from nowhere. Natural resources and the creativity of humans are
the primary resources for all that we do.
2. Fast change is the norm and we need considered and creative responses to
adapting to change.
3. Sustainable development is about enlightened self-interest not altruism.
4. The road to sustainability (or should that be the railway) is not a quick fix but a
series of stepping stones.
Corporate social responsibility (CSR) is essentially about how business takes

account of its economic, social and environmental impacts in the way it operates –
maximizing the benefits and minimizing the downsides. The U K Government sees CSR
as the voluntary actions that business can take, over and above compliance with
minimum legal requirements, to address its own competitive interests and the interests
of wider society. It is about the behaviour of private sector organizations and their
contribution to sustainable development goals.
8 Currently, there is also a new International Standards working group developing a standard drawing on this
and other documents to develop the phased implementation approach to EMS at international level.
9 The British Standard, BS 8900 – Guidance for managing sustainable development – is now available.
71
Table 8: Common ground between the relevant management systems
72

Key element ? Environment including waste Quality (I SO 9000) Health and safety (BS 8800) Sustainability/CSR
Top management ? ? ? ?
commitment
Policy ? Policy required ? Policy required ? Policy required Policy facilitates implementation
Planning Aspects and impacts Quality planning Risk assessment CSR issues and establish
Legal and other requirements Risk control values, decision making
Objectives and targets Objectives processes and behaviour
Environmental management Performance standards
programmes
Implementation Structure and responsibility Organization Risk control Stakeholder analysis and
Training Training Hazards documentation engagement
Communication Control – document, data, Document control Resource allocation
Document control design, process, customer Accident procedures Assessment of risks and
Operational control supplies Site rules opportunities
Emergency preparedness and Procedures Performance management Establish objectives and
response Purchasing techniques opportunities
Handling and servicing
Product ID
Measuring Monitoring and measurement Inspection and testing Performance standards Establish performance indicators
performance Corrective and preventive actions Techniques Premises, plant and equipment
Records Control of monitoring People, procedures and systems
equipment Reactive monitoring (corrective
Control of non-conformance actions)
Corrective and preventive Active monitoring (preventive
actions actions)
Control of quality records
Auditing EMS audit Internal quality audit Regular and systematic reviews Audit progress to achieving
Commitment to continual and independent audits objectives
improvement Commitment to continuous
improvement
Reviewing Top management review of entire Management review Management review to improve Review progress
performance system performance and further develop and associated management
health and safety practice systems
Report progress
6 . WASTE M AN AG E M E N T I N RE LATI O N TO OTH E R M AN AG E M E N T SYSTE M S
We have tried to show waste management does not exist in isolation and shares signif-
icant common ground with other management systems. At the simplest level, waste
management is a significant element of wider environmental management. This is signif-
icant because, with energy efficiency measures ( which might also be considered ‘waste’
management) , it represents the greatest potential to add value to the bottom line, is the
most regulated area of your business, and improves environmental performance. Those
implementing an environmental management system find the quick benefit areas here.
Often, simple changes and minor investment will produce great returns. In practice and
over time, tackling waste issues becomes the ‘way in’ to develop a full EMS.
It is perhaps worth reminding yourself about some of the key issues implicit in these
management systems. Answer yes or no for each question:
Question Env. Q H&S CSR
1 Does your organization meet applicable (waste)

regulations – in the U K or beyond?
2 Does your organization comply with health and safety
regulations – in the U K or beyond?
3 Does your business have to meet customer quality
requirements? (If so how?)
4 Does your business have to meet identified stakeholder
requirements? (If so how?)
4 Do you have a written policy in any of the four areas and
is it available?
5 Does the policy:
• acknowledge internal and external drivers?
• identify hazards?
• assess risks?
• define control measures?
• set out responsibilities?
• require training?
7 Do you have procedures to monitor policy in action?
8 Do you keep adequate records?
9 Do you measure and monitor?
1 0 Do you take action to correct any non-conformity?
1 1 Do you have good relationships with your regulators?
1 2 How much duplication of effort is there?
Do you have separate policies, procedures and personnel
to manage each issue?
73
If you have answered ‘no’ to any of these questions, then look again at the sources of 1
help and advice you have, both internal and external. For ‘yes’ answers, review the 2
information you have about each issue, and consider how an integrated approach may 3
be developed. 4
6
6 .4 I n teg ra ti on i n pra cti ce
7
8
To implement a joint management system, four areas need consideration:
9
1 . required action; 10
2. monitoring progress; 1
3. a management manual; 2
4. continual improvement. 3
Req u i red acti on 5
6
In many sections of this report we’ve talked about action – collecting information, making
7
the relationships internally and externally, preliminary communications and more
8
detailed considerations of a communication and training strategy. Alone, this wealth of
9
data and networking is worth little to your business. An action plan for implementing
20
a combined management system will draw together key findings and conclusions to tease
1
out exactly what action steps need to be taken to realize the benefits identified.
2
There are three areas to think about to develop a waste action plan. 3
4
• What needs to be done? 5
• Objectives and targets 6
• Implementation 7
8
Wh at n eed s to be d on e?
9
The waste review will have identified the key areas needing management action for effec- 30
tive waste action. This basic review system can also be used to gather information about 1
health and safety, quality and CSR management issues for the organization. 2
3
Obj ecti ves an d targ ets
4
Set objectives and targets based on what makes sense and this will advise actions. Consider 5
the three priorities for a combined system: 61
74
Priority 1 . ‘Must do’ activities. For example to comply with existing legislation or
customer requirements, or to bring immediate cost savings.
Priority 2. Any actions that make organisational sense, but are not so pressing. For
example, those bringing medium-term cost savings or those that satisfy anti-
cipated or actual customer needs.
Priority 3. Any actions that will require longer-term planning and investment.
A realistic timetable to start, carry out and finish each action is needed alongside these
priority areas. Trying to implement any management system all at once is a recipe for
disintegration. Although equipment, process or systems changes might be necessary, posi-
tive actions of staff are the foundation of sustained change. It is much more realistic to
break down your implementation strategy into a series of smaller steps that can be
achieved rather than trying (and perhaps failing) to tackle everything at once.
This process of considering ‘area – target – timetable – key players’ should be consid-
ered for each issue in the organization. The issues that arise can be ranked as they are
considered.
Area Target Timetable Key players

Table 9: An outline action
Waste Reduce waste costs/ plan
increase income
– segregate scrap metals – from new skip lease site manager/
– improve purchasing period contractors/
specifications – at supply contract waste regulators
– reduce office wastes negotiations buyers/suppliers
– November office personnel
Health Satisfy any outstanding legal – immediately Health and safety

and regulations manager
safety Maintain and extend legal – December Senior manage-
compliance ment
Energy Reduce consumption staff/site manager

(another – heating by 8% – May production
manifestation – machines by 5% – Winter manager
of waste) – electricity by 1 1 % – March operations staff
Product and Investigate sources of raw – Spring Purchasing

process materials manager
Cost new machines and – November Plant manager
investigate environmental Finance manager
issues
75
Activity 1
2
Now consider the issues of your organization and draft an action plan using the four
3
headings: ‘area – target – timetable – key players’.
4
5
Implementation
6
Each goal will require its own set of actions. This can be considered the implementa-
7
tion stage of an action plan. It has seven steps, the detail for which will vary from issue
8
to issue.
9
10
An implementation plan:
1
Step 1 – The data 2
3
Look at the total information for the organization.
4
5
– Where is the greatest environmental impact – from waste, quality, health and safety
6
or CSR?
7
– What are the causes?
8
– What could be done to reduce impact or costs?
9
– What could be done to improve the situation?
20
Step 2– The key players 1
– Who are the key staff involved – internal and external? 3
– What are their feelings and ideas? 4
– How can they contribute? 5
6
Step 3 – The targets 7
Reach consensus on what the targets are to satisfy legislation and reduce impacts and 8
costs. 9
30
Step 4 – The plan 1
Agree a plan of campaign with the key staff involved. Include: 2
– the proposed actions and changes; 4
– the responsibilities and the time frame; 5
– resourcing required. 61
76
Step 5 – Ownership
Everyone involved – either directly or indirectly – must be fully committed and back the
plan. This must include senior management. Training and communication work will
reveal complementary activities here.
Step 6 – Do it
Having reached consensus, make sure the plan is carried out.
Step 7 – Monitor progress

The process will need to be managed, monitored and evaluated, fine- tuning each of the
phases as necessary.
Case study – storage of

To help understand the many facets of integrating different types of management waste
systems, consider the following case study.
The example company is a medium-sized enterprise with 250 staff. The site is a busy
depot, autonomous from other parts of a larger company. Within the depot there is a
managing director, financial director and personnel director, support staff,
administrative office staff, shop floor supervisors, drivers and manual staff (including
two canteen staff).
The type of activities on site include invoicing, purchasing and administration duties,
unpacking incoming materials and repackaging and storing of products, and vehicles
for the distribution of products. The small staff canteen offers hot and cold drinks,
prepacked sandwiches, crisps, cakes, etc. and a small selection of heated items.
Such a site will obviously be producing many different types of waste. Take a moment
to write a list of what you think could be produced.
You may have come up with items such as:
– paper and packaging (card and plastic);
– issues with maintenance of vehicles and waste products;
– glass and metal containers;
– old electrical and electronic items, e.g. telephones, computers, old refrigerators
etc.;
– the potential for food waste from the canteen.
For the site there is an assumption that there is a weekly collection of waste – so the
issue is storage of waste on site between collections (including the potential need to
separate materials).
Since these materials may take up space and have to be controlled, there are many
management issues that might be relevant here, primarily from an environmental but
also health and safety perspective. Traditionally these may have been dealt with
separately with different procedures (albeit with a similar aim – to control the ‘risks’ the
77
1
situation or materials represent), but there are potential benefits from treating these
simultaneously, with both perspectives being considered. This of course would have to 2
take into consideration associated legislative requirements. 3
Consider what the main implications could be regarding the situation described. 4
Outline some of the issues that could be both health & safety and environmental, and
5
the practical difficulties the company might face while dealing with these.
6
Issues could be:
7
• Environmental legislative requirements:
8
relevant packaging legislation;
legislative requirements regarding the hazardous nature of oils etc. and separate 9
environmental disposal of tyres;
10
WEEE regulations for electrical and electronic equipment;
duty of care and determining different categories of waste if required to do so by 1
law.
2
• Health and safety: 3
Health and Safety at Work Act, COSH H and other health and safety legislation
potentially to do with noise if machinery is used; 4
most importantly – risk assessment of the materials and handling. 5
General practical points 6
1 ) SPACE: Different types of waste may need to be stored separately, e.g. separate 7
storage areas for hazardous and non-hazardous waste, segregation of different 8
hazardous wastes (remembering old computers and refrigerators fall under both
WEEE and hazardous waste requirements) – they may also have different containers 9
for recycling initiatives where issues of contamination are important. 20
2) LOCATION : Waste should potentially be stored undercover, out of direct sunlight, 1

wind and rain. If non-hazardous, unsealed containers would be sufficient, e.g. wheeled
2
bins or skips. Hazardous waste could require tanks or drums and very likely bunded
areas. 3
3) SECURITY: Waste should also be secure from the general public and signposted 4
so everybody on site knows where it is. If compaction equipment is used this may
5
require risk assessment.
6
4) CONTAI N ERS : Containers should be adequately labelled both for health and safety
(potentially COSH H) but also for source and disposal requirements. This is particularly 7
important if a number of different wastes are handled or stored in the same location.
8
5) QUANTITY: Storage should be kept to a minimum. Good housekeeping and 9
minimization practices are good from the health and safety and environmental
perspective, and reduce risks associated with storage of large quantities of hazardous 30
materials. 1
6) MANAGEM ENT PROCEDURES : Health and safety procedures for hazardous 2
waste may need to be initiated alongside environmental procedures, to ensure they do
not mix with normal waste, and to ensure hazardous waste does not end up with 3
controlled waste (legal issues) or vice versa (cost issues). Procedures may also be 4
needed for dealing with spillages during the storage, loading, transportation and
unloading of wastes. 5
61
78
Monitoring progress
The requirements for a combined management system should now be clear and it is
important to verify that what should be happening is actually happening. For example,
in collaboration with one of the regulators your work might have established a new action
on a legal requirement for your operations. If hazardous or special wastes are produced
and exceed the permitted levels, then not only could human health be jeopardized, but
also fines could be placed on the organization. Effective monitoring and corrective action
will help to avoid such damaging occurrences.
Progress needs to be monitored on two levels.
Level 1 – The micro level
This is the monitoring of progress towards each goal in an action plan and the fine-
tuning of the process as knowledge increases over time. It is vital to establish a regular
monitoring programme as a cornerstone of an integrated management action plan.
Computer-based information management systems can help deal with the growth in data
and make sense of it. These can be set up to provide prompts to regularly monitor
progress.
Level 2 – The macro level
Extending your waste review to include quality and health and safety will provide base
line data for an integrated management system. Regular auditing to find out how well
you are performing is vital. Even if your business is performing well from a financial
perspective, you still need to carry out financial audits to verify the results and to prevent
any shocks! Exactly the same reasoning needs to be applied to the verification of your
integrated performance. It may be even more important, as a breach of any associated
legislation may have a disturbing effect on the organization.
A combined management manual

The manual sets out established procedures for waste, environment, quality and health
and safety management, and provides the key point of reference. The manual should
become the point of reference for the organization and, most importantly, for those staff
with day-to-day responsibility for implementation of the systems. To be effective it needs
to gather users not dust, and should be designed to be accessible, not just take up shelf
79
space! It does not necessarily have to be paper-based. It could be an online system with 1
controlled access so that those who need to use it can extract what they require and add 2
comments and suggestions for the management representative who looks after it. 3
4
To be effective any management manual needs to:
5
6
• be clear and simple;
7
• be written in straightforward not technical language;
8
• be as short and accessible as possible;
9
• use charts and diagrams to bring the information to life;
10
• be dynamic and easily updated;
1
• be available to all who need access to it.
2
3
As with any new initiative, it makes sense to produce a draft first and present this to
4
colleagues. Some sections of the manual will relate to relationships with regulators.
5
Assuming there are not issues of commercial confidentiality, then a dialogue with regu-
6
lators at this drafting stage will improve the final version.
7
Once an executive summary has been added, the final draft manual can be presented 8
and circulated to key colleagues for comment. Feedback from colleagues will allow the 9
final version to be produced and the manual formally released within the business as 20
part of your communication and training strategy. 1
3
A small business we worked with has put together just such a manual and they call it
their ‘Waste Handbook’. Basically it’s an A4 ring binder folder with plastic sheaths over 4
various key documents relating to the company (their Waste licences, their H&S 5
policies, and other relevant reference materials). So if they want to reference about
waste the manager asks to see the handbook and it’s all there in one place. 6
8
Continual improvement 9
Effective management is a continuous process, not a finite programme. This section will 30
help in establishing a map of the territory and in gathering the information needed for 1
the journey. The process should be well in place and become simply another compo- 2
nent of good management. This may be enough in itself. The implementation of effective 3
management is more than just an obligation or expense. It will provide cost savings, 4
increase profits and market share, and reduce negative impacts on staff and the envi- 5
ronment. Effective management must always make organizational sense. 61
80
Table 10: Checklist for an

Contents
integrated management
Purpose of the manual and a description of your management systems manual
Your policies for waste, environment; quality, health and safety, and CSR
Issue-specific actions for:
– energy;
– water;
– raw materials;
– process and product;
– site;
– paper and packaging;
– discharges;
– transport;
– contractors;
– community;
– identified stakeholders.
Your implementation plans for each issue, including targets and timescales
Roles and responsibilities – the key players
Legislative requirements
Communication process and programme
Training process and programme
Monitoring/auditing process & programme
Appendices: To include related procedures and work instructions

Data for each issue
Related policy documents and plans
Computer record systems
Regulations and permits
Notes on management committee meetings
Incident reports and emergency plans
Perhaps the ultimate goal is to create a healthy, high quality business with minimum
environmental impacts. The best organizations are already turning benefit into business.
Some measures of organizational health are listed below. In practice they are much more
than ‘motherhood and apple pie’. How many can you say yes to?
Less time lost through health- related absenteeism Yes/No
Reduced occurrence of health and safety, quality,
CSR and environmental incidents Yes/No
Improved morale Yes/No
81
A positive attitude to training and taking action Yes/No 1
Fewer grievances Yes/No 2
Greater loyalty Yes/No 3
Improved timekeeping Yes/No 4
Lower staff turnover Yes/No 5
Recruitment of excellent staff Yes/No 6
Less time lost due to workplace disputes Yes/No 7
An adaptive culture and flexible workforce Yes/No 8
Held in high regard by the local community Yes/No 9
Fewer or no defective products delivered Yes/No 10
Increased output and productivity Yes/No 1
Lower level of machine downtime Yes/No 2
More new business Yes/No 3
Reduced customer complaints Yes/No 4
Higher sales Yes/No 5
All of these are outcomes of an effective integrated management system. All have a cost 7
attached to them. All make the difference between success and failure for an organiza- 8
tion, and all can be outcomes of an integrated management system. 9
20
Finally, if it doesn’t make sense to integrate then don’t. Running an integrated system is
1
an option, not an absolute necessity. However, make sure you have an open and contin-
2
uous dialogue with your colleagues to share ideas and understanding of what each of
3
you are doing.
4
5
Activity 6
Consider what you have read in this chapter regarding integration of various manage- 7
ment systems, then take some time to review how this could apply in your organization. 8
• Outline a case for integrating environmental and health and safety management within 9
30
a company such as your own.
1
o What arguments might there be against integration?
• What issues might influence the setting of priorities for action when implementing
2
3
an integrated management system?
4
Once you have considered these questions turn to Appendix 4 to review the answers that 5
you could have included. 61
82
Waste terminology 7
Summary
This chapter sets out some of the main terms associated with waste and waste
management.
Best Practicable Environmental Option (BPEO): First introduced by the Royal Com-
mission on Environmental Pollution in 1 976, this is the outcome of a systematic consul-
tative and decision making process which emphasizes the protection of the environment
across land, air and water. It establishes, for a given set of objectives, the most practicable
option that provides the most benefit, or least damage, to the environment as a whole, at
acceptable cost in the long and short term. Essentially it is an analysis of alternatives.
It was introduced into waste planning in the UK Government strategy document, Making
Waste Work: A Strategy for Sustainable Waste Management (1 995) .
Black list: The EU Framework Directive (76/464/EEC) list of 1 29 substances considered
to be so toxic, persistent or bio-accumulative in the environment that priority should
be given to eliminating pollution by them.
Controlled waste: According to section 75(4) of the Environmental Protection Act, 1 990,
‘controlled waste’ means household, industrial and commercial waste or any such waste.
Controlled waste is governed by the Controlled Waste Regulations, 1 992 . Waste does not
have to be hazardous or toxic to be a controlled waste.
Controlled waste does not include waste from any mine or quarry, or sewage or waste
from premises used for agriculture. However, certain types of litter and refuse are treated
as controlled waste.
Within these three types of controlled waste, a further subdivision can be made into
hazardous and non-hazardous wastes depending on the effect of these wastes on health
and environment.
83
Duty of Care 1
2
The Duty of Care is a law (embedded in the Environmental Protection Act 1 990) which
3
says that you must take all reasonable steps to keep waste safe. If you give waste to
4
someone else, you must be sure they are authorized to take it and can transport, recycle
5
or dispose of it safely. If you are a business or industry, the duty of care applies to you.
6
Commercial, industrial, household wastes and special wastes are classified as ‘controlled
7
waste’. The duty of care applies to all controlled waste – this means that waste materials
8
produced as part of your business or within your workplace are regulated by law and
9
are subject to the duty of care.
10
Effluent: Liquid waste released into the environment from industrial, agricultural or 1
sewage treatment plant. 2
3
European Waste Catalogue: The European Waste Catalogue classifies waste materials and
4
categorizes them according to what they are and how they were produced.
5
6
Hazardous waste: European Council Directive 91 /689/EEC (the Hazardous Waste
7
Directive, or HWD) sets the framework within member states of the European Com-
8
munity for provisions to control the movement of arisings of hazardous wastes.
9
Hazardous waste is essentially waste that contains hazardous properties that may render 20
it harmful to human health or the environment. The European Commission has issued 1
a directive on the controlled management of such waste (91 /689/EEC) and hazardous 2
waste is defined on the basis of a list, the European Waste Catalogue, drawn up under 3
that directive. Hazardous waste now includes, for example, end-of-life vehicles, fluores- 4
cent tubes and pesticides. 5
6
The term special waste became obsolete in England and Wales in July 2005, when the
7
new hazardous waste regime replaced the special waste regime.
8
9
Hierarchy of waste: The waste hierarchy is a concept that provides a framework within
30
which the most desirable waste management options are set out, see Figure 9.
1
• Elimination: Not creating waste in the first place so that there is no need for reuse, 2
recycling or disposal, is the most environmentally desirable option. 3
• Reduction: Using technology that requires less material in products and produces less 4
waste in manufacture, and by producing longer lasting products with lower pollution 5
potential. 61
84
7. WASTE TE RM I N O LO GY
Figure 9: Hierarchy of
waste
Eliminate
Reduce
Eliminate Reuse
Recycle Policy
Reduce support
Energy
Reuse recovery
Recycle Dispose
Energy
recovery
Dispose
• Reuse: Waste reuse involves the multiple use of a product in its original form, with
or without reconditioning, for its original or an alternative purpose – e.g. re-granu-
lating processing of ‘scrap’ plastic or recharging batteries.
• Recycling: Using waste materials in manufacturing other products. In this way, value
is recovered and waste becomes a useful input into another process.
• Disposal (to landfill) : This is only an option if none of the other options is appro-
priate. If biodegradable waste is landfilled, energy recovery through methane capture
should be considered.
Incineration without energy recovery is not normally considered to be a viable option.
IPPC – Integrated Pollution Prevention & Control: These regulations replaced the
Environmental Protection Act 1 990 and lay down measures designed to prevent or reduce
emissions to air, water and land. IPPC represents a major overhaul of legislation and has
a significant business impact.
Packaging: All products made of any materials of any nature to be used for contain-
ment, protection, handling, delivery and presentation of goods or services from the
producer to the user or consumer.
Packaging waste: Any packaging or packaging material covered by the definition of waste
(see below) , but not including production residues.
85
Polluter pays principle: The principle that the cost of preventing pollution or of mini- 1
mizing pollution damage should be met by those deemed responsible for the pollution. 2
Prescribed processes and substances: A complete list can be found in The Prescribed 4
Processes and Substances Regulations 1 991 . 5
6
Recycling: The reprocessing in a production process of waste materials for the original
7
purpose or for other purposes including organic recycling, but excluding energy recovery.
8
9
Red list: 23 toxic substances defined in the UK as those presenting the greatest poten-
10
tial threat to the environment. Included are some heavy metals, certain pesticides and
1
solvents.
2
3
Registered carrier: Anyone who in the course of their business or in any other way profits
4
from transporting controlled wastes. They must be registered to do so with the
5
Environment Agency (England & Wales) , SEPA (Scotland) or EHS (Northern Ireland) .
6
7
Segregation: The physical separation of waste into its constituent parts, thereby making
8
it ready for reuse or disposal. The Hazardous Waste Regulations (2005) mean all
9
hazardous waste needs to be segregated, the end of the line for the ‘Special Waste Skip’.
20
1
Treatment of waste: This can be physical (e.g. bailing, sorting, pulverizing, compacting
2
etc) or chemical (e.g. neutralizing) . It can include treatment prior to storage, prior to
3
transportation and prior to disposal.
4
Waste – legal definition: ‘Any substance or object the holder discards, intends to discard 5
6
or is required to discard’ is ‘waste’ under the Waste Framework Directive (European
7
Directive 75/442) .
8
Once a substance or object has become waste, it will remain waste until it has been fully 9
recovered and no longer poses a potential threat to the environment or to human health. 30
The Environment Agency considers waste to remain waste until fully recovered. 1
Waste management licence: This is the licence issued by the Environment Agency or its 3
equivalent in Scotland or Northern Ireland to those wishing to operate a waste manage- 4
ment site or to deposit, recover or dispose of controlled waste. It is illegal to operate 5
without a licence unless a letter of exemption is obtained. 61
86
7. WASTE TE RM I N O LO GY
Waste broker: Those who make arrangements on behalf of others to dispose of waste.
They are required to register with the Environment Agency.
Waste carrier: Those who are registered to transport controlled waste by road, rail, air,
sea or inland waterways. The registration scheme is implemented by the Controlled Waste
(Registration of Carriers and Seizure of Vehicles) Regulations 1 991 .
Waste holder: Producer of the waste or person in possession of it.
Waste producer: Anyone whose activities produce waste, or anyone who carries out pre-
processing, mixing or other operations resulting in a change in the nature or composition
of this waste.
Waste Transfer Note: A Waste Transfer Note ( WTN) is a document that must be
completed and accompany any transfer of waste between different holders. The WTN
must contain enough information about the waste – including the correct European
Waste Catalogue code – to enable anyone coming into contact with it to handle it safely
and either dispose of it or allow it to be recovered within the law. Failure to give enough
information may result in prosecution.
Waste stream: Waste streams vary considerably and may include either a range of mate-
rials when treated together or single items such as empty drums or plastic off-cuts of
the same material. A waste stream is identified partly by its composition and also by the
manner in which it is dealt with, i.e. type of container, location, disposal method and
contractor details. Where these are constant a waste can be classified as a single stream.
Waste trail: An auditable trail that follows waste from creation to collection, storage,
transportation and disposal.
WEEE Directive: The Waste Electrical and Electronic Equipment (Producer Responsi-
bility) Regulations (2002/96/EC) . The directive aims to prevent WEEE arising, encourage
reuse, recycling and recovery of WEEE, and improve the environmental performance of
all operators involved in the lifecycle of electrical and electronic equipment, especially
those dealing with WEEE.
87
1
10
20
30
61
Gateways to help and support 8
Summary
This chapter provides a few authoritative sources of help, both at a national and
local level. They are split between three broad areas of information need:
1 . legal concerns about waste;
2. general enquiries about waste;
3. technical issues about waste.
As a general starting point we suggest calling the Envirowise Helpline on 0800 585794
8.1 Legal issues
Regulatory agencies
Environment Agency http:/www.environment-agency.gov.uk
08708 506 506
Scottish Environment http:/www.sepa.org.uk
Protection Agency 01 786 457700
Environment & Heritage http://www.ehsni.gov.uk/environment/
Service (Northern Ireland) environment.shtml
028 9054 6450
National helpline
Environment & Energy Helpline http://www.envirowise.gov.uk/
email direct from website
0800 585794
This free helpline provides advice direct to the caller, or directs the caller to the most
appropriate source of help.
89
8.2 General enquiries 1
Environment & Energy Helpline http://www.envirowise.gov.uk/ 3
email direct from website and links to regional 4
offices 5
0800 585794 6
7
Environment Agency http://www.environment-agency.gov.uk/
8
see website for regional contacts
9
08708 506 506
10
1
Arena Network Wales http://www.arenanetwork.org/
2
info@arenanetwork.org
3
01 443 844001
4
5
Arena Northern Ireland http://www.bitc.org.uk/regions/bitc_in_your_
6
region/northern_ireland/programmes/
7
environment/arena_ps.html
8
email direct from website
9
(028) 9046 0606
20
Green business clubs 1
2
See Business in the Environment below.
3
4
8.3 Technical enquiries 5
6
Environment & Energy Helpline http://www.envirowise.gov.uk/
7
– Envirowise email direct from website
8
0800 585794
9
30
British Glass Manufacturers http://www.britglass.org.uk/BritishGlass/
1
Confederation BritishGlassHome.html
2
info@britglass.co.uk
3
01 1 4 290 1 850
4
British Metals Recycling http://www.recyclemetals.org/index.shtml 5
Association 01 480 455249 61
90
8. G ATEWAYS TO H E LP AN D S U PPO RT
British Plastics Federation http://www.bpf.co.uk/
bpf@bpf.co.uk
020 7457 5000
Confederation of Paper Industries http://www.paper.org.uk/recoveredsector/about.htm
cpi@paper.org.uk
01 793 889600
Chemicals Industries Association http://www.cia.org.uk/newsite/
enquiries@cia.org.uk
020 7834 3399
WRAP – The Waste & Resources http://www.wrap.org.uk/
Action Programme email direct from website
0808 1 00 2040
CIWM – Chartered Institution http://www.ciwm.co.uk/
of Wastes Management technical@ciwm.co.uk
01 604 620426 (0900 – 1 700 hours)
The Compost Association http://www.compost.org.uk/
membership@compost.org.uk
08701 60 3270
8.4 Other useful contacts

Business in the Environment http://www.bitc.org.uk/environment/index.html
information@bitc.org.uk
0870 600 2482
Groundwork Foundation http://www.groundwork.org.uk/
info@groundwork.org.uk
01 21 236 8565
Waste Exchange UK http://www.wasteexchangeuk.com/
info@wasteexchangeuk.com
01 453 756688
91
Waste Exchange Services http://www.wasteexchange.com/ 1
info@wasteexchange.com 2
01 642 442 080 3
4
Waste Management Industry http://www.wamitab.org.uk/
5
Training & Advisory Board info.admin@wamitab.org.uk
6
01 604 231 950
7
8
Waste Watch http://www.wastewatch.org.uk/
9
info@wastewatch.org.uk
10
020 7549 0300
1
2
Government Sources http://www.defra.gov.uk/environment/waste/
3
index.htm
4
Environmental Businesses and http://www.edie.net/ 5
Suppliers 6
7
Waste Law Resource http://www.wastelaw.co.uk/Intro/
8
9
What is hazardous waste? http://www.hazardouswaste.org.uk/
20
1
Information on small businesses http://www.netregs.gov.uk/
2
and how to meet environmental
3
legislation
4
30
61
92
Appendix 1 :
Checklists for waste review
Checklists for waste review – see Chapter 4:

How to Manage Waste
PACKAGI NG AN D RAW MATERIALS

Area of business Contacted Interviewee Date
SOURCES OF RAW
MATERIALS PACKAGI NG
Questions Response Action
YES/NO?
How are raw materials sourced and
ordered to minimize waste?
How are supplies packaged?

What happens to the packaging?
How much do you pay for it?
Do you ask your suppliers to:

• minimize packaging supplied?
• offer alternative packaging types
e.g. cardboard pallets?
• ensure recycling/reuse as much as
they can?
Do you know whether you clients would:

• value less packaging (and a lower
price)?
• return used packaging to you for reuse?
(What would this mean for you if they
did?)
Could you sell ‘waste’ packaging?
Are there alternative suitable raw

materials available that would help you
reduce waste?
93
PRODUCT AN D PROCESS 1
Area of business Contacted Interviewee Date 2
3
PRODUCT & PROCESS Designers
Production staff 4
Buyers 5
Regulators
6
YES/NO? 7
Is the product(s) designed to: 8
• minimize waste? 9
• if yes, how? If no, why not?
10
Does specification influence the levels 1

of waste? If so, how?
2
Do you understand how your production 3

process(es) operate as far as waste
production is concerned? 4
5
How do you measure process efficiency?
6
Is waste an unavoidable output from the
process? 7
8
Where are wastes created in the process
and how are they disposed of? 9
20
Could any waste produced be sold at a
profit or given away? 1
2
What opportunities exist to prevent
or reduce waste? 3
4
How could you improve the product and
process to significantly reduce waste? 5
6
Have you talked to any of these outside
organization for help and advice: 7
• customers?
8
• regulators?
• trade associations? 9
• green business clubs?
30
61
94
APPE N D I X 1 . CH ECKLI STS FO R WASTE REVI EW
SITE MANAGEM ENT

SITE MANAGEM ENT Site supervisor

Health and safety officer
Store manager
Regulators
YES/NO?
What are the basic activities on the site?
How do they interrelate?
What are the wastes:

• received?
• produced?
• stored?
• disposed of?
Are the records of waste kept?

What form are they in?
Why are they produced and who for?
Where does waste show up in these
records?
How are materials stored on site?

Dos poor storage generate waste?
What is disposed of?

Where did it come from?
Why is it disposed of?
How is it disposed of?
Where does it go?
Do you/can you discuss your waste

issues with the regulators?
What help could the regulators provide?

How could you best engage their help?
95
UTI LITI ES 1
3
UTI LITES Production manager
Water Technical staff 4
Energy – electricity, gas and oil Site supervisor 5

Utility companies
6
YES/NO? 7
8
WATER
9
How much water do you use?
How much does it cost? 10
What are the disposal charges? 1
2
What trade effluents do you produce?
How much does disposal cost? 3
4
How could you reduce:
• water use? 5
• effluent produced? 6
How do you monitor these?
7
EN ERGY 8
What is your energy mix? 9

Where is it used? 20
When is it wasted?
1
Where is it wasted?
2
How do you measure and monitor energy 3
usage?
4
What preventative measures are already 5
in place to save energy?
6
What investments could you make to 7
minimize energy usage?
8
How much would the investment cost?
What is the estimated payback? 9
30
Where could energy used be minimized,
recovered or reused? 1
How could you do this? 2
61
96
EM I SSION S AN D DI SCHARGES
EMI SSION S AN D DI SCHARGES Plant manager

Production manager
Regulators
YES/NO?
What emissions and discharges does
your business produce:
• to air?
• to water?
• to land?
How are they created?

When are they created?
Where do they go?
Are they all controlled?
How are emissions monitored?

Who does the monitoring?
How are records kept and communicated
to relevant staff?
Do you know and understand your legal

requirements?
Do you meet them?
Could you reduce emissions:

• easily?
• where?
• with changes to production practices?
• when?
• with investment?
What would the payback period be?

What would be the effect on production?
What is essential action to stay legal?
What help do the regulators give?

How could you involve them more?
97
PAPER 1
3
PAPER Buyer
Office paper Designer 4
Packaging paper Staff 5

Sales
Customers 6
Questions Response Action 7
YES/NO? 8
How much paper do you use? 9

• By volume?
• By type? 10
1
Where is it used?
2
Where is it wasted?
How do you monitor paper use? 3
4
How much of this is waste?
• In total? 5
• As % of volume purchased? 6
What systems do you have for reusing 7
and recycling? 8
How could you change systems and 9
procedures to reduce paper? 20

• Through communication?
• Through use of electronics? 1
• Through better housekeeping? 2
30
61
98
PEOPLE
PEOPLE Training manager

Personnel officer
Suppliers/buyers/plant supervisors
YES/NO?
Which staff are directly involved in:
• waste management?
• waste handling?
Are they trained in:

• waste handling procedures?
• waste minimization?
• legal compliance?
What staff are ‘indirectly’ involved

in waste management (e.g. production,
design, buyers)?
Are new staff briefed to develop their

understanding of waste management
issues?
How are suppliers briefed to ensure their

compliance with your needs?
How is ongoing commitment to waste

management communicated to staff?
• Briefings?
• Works meetings?
• Notices?
• Newsletters?
Is this effective?
Do you have a waste policy?

Do staff know about it?
Do you report to staff on performance
against policy objectives?
How are staff involved in waste

management?
• Incentive schemes?
• Suggestion schemes?
99
TRAN SPORT AN D DI STRI BUTION 1
3
TRANSPORT AN D DI STRI BUTION Transport manager
Distribution manager 4
Suppliers/customers 5
Trade associations
6
YES/NO? 7
How do you organize your transport of 8
goods and services? 9

• Using your own vehicles?
• Using contractors? 10
1
How much does transport cost you?
2
How is distribution organized? 3

How does this match up with the
4
production process?
How could it be improved? 5
6
How do you involve suppliers and
customers in scheduling deliveries? 7
8
In which areas could you make savings:
• easily? 9
• with some investment of time? 20

• with some investment of money?
1
What would the payback be?
2
How are transport staff trained in
3
economical (less wasteful and safer)
driving techniques? 4
5
How could you make savings on energy
and fuel? 6
7
How are vehicles maintained and cleaned?
Is there room for improving the systems? 8
30
61
1 00
Appendix 2:
History of waste and recycling 10
In early pre-industrial times waste was mainly composed of ash from fires, wood, bones,
bodies and vegetable waste. It was disposed of in the ground where it would act as
compost and help to improve the soil. Ancient rubbish dumps excavated in archaeolog-
ical digs reveal only tiny amounts of ash, broken tools and pottery. Everything that could
be was repaired and reused, populations were smaller, and people lived in less concen-
trated groups. However, the transition from nomadic hunter-gatherer to farmer meant
that waste could no longer be left behind, and it soon became a growing problem.
Until the Industrial Revolution, when materials became more available than labour, reuse
and recycling was commonplace. Nearly 4,000 years ago there was a recovery and reuse
system of bronze scrap in operation in Europe, and there is evidence that composting
was carried out in China. Reuse and recycling has always existed in the form of salvage,
an age-old tradition stretching forward to the rag-and-bone men. Traditionally, recov-
ered materials have included leather, feathers and down, and textiles. Recycling included
feeding vegetable wastes to livestock and using green waste as fertilizer. Pigs were often
used as an efficient method of disposing of municipal waste. Timber was often salvaged
and reused in construction and ship-building. Materials such as gold have always been
melted down and recast numerous times. Later recovery activities included scrap metal,
paper and non-ferrous metals.
However, as city populations increased, space for disposal decreased, and societies had
to begin developing waste disposal systems.
Chronology of waste
3000 BC – In the Cretan capital, Knossos, the first recorded landfill sites are created
where waste is placed in large pits and covered with earth at various levels.
2000 BC – Composting is known to have been a part of life in China. During the European
Bronze Age bronze scrap recovery systems were in place.
1 0 Reproduced with permission of Waste Watch, a leading national organisation promoting and encouraging
action on the 3Rs – waste reduction, reuse and recycling. www.wastewatch.org.uk.
1 01
Over 2,500 years ago , government officials in the Greek city-state of Athens open a 1
municipal landfill site and decree that waste is to be transported at least one mile beyond 2
the city gates. 3
4
1 297AD – In response to the increasing amount of waste deposited in towns in Britain,
5
a law is passed to make householders keep the front of their house clear from refuse. It
6
is largely ignored. However, most waste is burned on households’ open fires.
7
8
1 354 – ‘Rakers’ are employed in each London ward to rake rubbish together, load it onto
9
carts, and remove it once a week.
10
1 407 – It is ruled that household rubbish is to remain indoors until it can be removed 1
by the rakers, after which it is either sold as compost or dumped in the Essex marshes. 2
This preliminary attempt to manage and control waste is not particularly successful, but 3
paves the way for further regulation. 4
1 408 – Henry IV’s removal order instructs that refuse be removed or else forfeits be paid. 6
7
Medieval German cities require the wagons which bring produce into the city to carry
8
out waste into the countryside.
9
20
1 500s – Spanish copper mines use scrap iron for cementation of copper, a recycling prac-
1
tice that survives to this day.
2
1 51 5 – Stratford-upon-Avon court records show that Shakespeare’s father was fined for 3
‘depositing filth in a public street’. 4
5
1 588 – Elizabeth I grants special privileges for the collection of rags for papermaking. 6
7
1 700s and 1 800s – The Industrial Revolution begins in the 1 8th century when the avail-
8
ability of raw materials and increased trade and population stimulate new inventions
9
and the development of machinery.
30
1
Coal-powered machinery can now produce increasingly large quantities of materials
2
quickly and cheaply. Increased production has led to increased waste, which lays in place
3
the means of mass producing materials that we see in factories today.
4
Early 1 800s – Many people live by selling what they can find in other people’s rubbish, 5
even dogs’ dung, which is valuable as it is used by tanners for purifying leather. 61
1 02
APPE N D I X 2 . H I STO RY O F WASTE AN D RECYCLI N G
‘Toshers’ work in the sewers, a dangerous and smelly way to make a living, but lucrative
as they find coins, bits of metal, ropes and sometimes jewellery.
‘Mud-larks’ scavenge on the river banks, and make a very poor living.
‘Dustmen’ collect the ash from coal fires. Over three and a half million tons of coal are
burned in London in a year!
The dust is taken to dust-yards. Here men, women and children work on the heaps of
rubbish, sieving the breeze or coarse section of the dust. This is used as a soil condi-
tioner and for brick making.
1 848 – In Britain the Public Health Act 1 848 begins the process of waste regulation.
1 874 – Energy from waste begins its development in Britain as the first ‘destructor’ is
designed and constructed in Nottingham. Destructors were prototype incineration plants
that burnt mixed fuel producing steam to generate electricity. Over the next 30 years,
250 destructors are built in Britain. They are opposed on the grounds of emissions of
ashes, dust and charred paper that fall onto the surrounding neighbourhood. By 1 945
incineration is at an all-time low, to re-emerge in the 1 960s and again today, where oppo-
sition is on the grounds of dioxin emissions.
1 875 – The Public Health Act 1 875 charges local authorities with the duty to arrange
the removal and disposal of waste, starting an evolution of local authority power. This
replaces the previously widespread practice of scavenging. The act also rules that house-
holders keep their waste in a ‘movable receptacle’, the beginning of the dustbin, which
the local authorities have to empty every week. A charge could be made for every day
the bin was not emptied.
1 890 – The British Paper Company is established specifically to make paper and board
from recycled materials. Waste paper is obtained from organizations such as the Salvation
Army and rag-and-bone men.
By the late 1 800s household waste is collected daily in moveable ash bins. The waste is
sorted by hand, usually by women or girls, into salvageable materials, and coarser mater-
ials are sieved from fine ash (breeze) . A large proportion of the waste is salvaged, revealing
the extent of reuse and recycling systems, for instance materials such as glass and metal
are returned to merchants, and the breeze and hard core from incinerated residue are
1 03
used in building materials. The value of goods reclaimed from dust heaps shows that 1
the level of recycling and reclamation has always depended on economic incentive. 2
3
1 898 – The Association of Cleansing Superintendents is established, which today has
4
evolved into the Institute of Wastes Management.
5
6
1 907 – An amendment to the Public Health Act 1 875 extends refuse collection to include
7
trade refuse and authorizes local authorities to levy charges for waste collection.
8
9
1 907 – A delegate at the Association of Cleansing Superintendents conference is quoted
10
in the Surveyor as suggesting that the biggest change in municipal work would be the
1
change from destruction to salvage ‘in the near future’. Nine decades on this has still not
2
happened.
3
1 921 – The British Waste Paper Association is established (initially as the Association of 4
London Waste Paper Merchants) to help develop the trade in waste paper for recycling. 5
6
1 930 – The Ministry of Health urges that ‘the system of dumping crude refuse without
7
taking adequate precautions should not be allowed to continue’. Similar complaints about
8
unsanitary landfill were to continue for several decades.
9
20
1 930s – The manufacture of plastics from chemicals produced from petroleum begins
1
(plastic products had been made from plants since 1 862) . The production and manu-
2
facture of plastics grows slowly over the next 20 years. In the economic boom of the
3
1 950s production begins increasing sharply due to increases in different types and appli-
4
cations for plastics. While the development of plastics and other forms of packaging has
5
reduced the amount of food wastage, the environmental consequences of increasing
6
amounts of non-biodegradable plastic packaging and toxic inks is largely overlooked.
7
8
In the 1 930s, most people live in houses where heating and hot water are provided by
9
burning newspaper and coal in fires, hence the small quantities of paper and large quan-
30
tities of dust in the bins. The small percentages of textiles, glass, and metals are also the
1
result of recovery and reuse schemes.
2
1 936 – The Public Health Act 1 936 rules that the accumulation of waste that is preju- 3
dicial to health, or a nuisance, is a Statutory Nuisance. Authorities are given the power 4
to prosecute over uncontrolled dumping, cesspools and scavenging – a practice that often 5
resulted in the scattering of refuse. The act also prohibits building upon contaminated 61
1 04
land and lays down regulation for the management of landfill sites, but these were mostly
overlooked in the years that followed.
During the world wars waste regulation becomes less of a priority. Despite a rise in recla-
mation and recycling during the wars, the post-war years face the legacy of huge
unsanitary and uncontrolled refuse tips especially surrounding the larger cities. Although
local councils make efforts to legislate against the dumping of refuse, appalling situa-
tions develop throughout the country, where vast tips up to a mile long burn continuously.
1 947 – The Town and Country Planning Act gives authorities planning powers over new
waste management sites, but most of the existing tips cannot be controlled.
During the post-war years, economics are against incineration, hence the domination of
landfill in British waste disposal practice. Landfills are constructed at the most convenient
cost and locations, with little thought of their environmental impact or consequences such
as water pollution and methane gas. Contemporary consumer society evolves with the
increase in production and consumption, as products are designed to be thrown away and
packaging increases. Increased consumption inevitably generates an increase in manu-
facturing, industry, mining and quarrying, agricultural and food processing wastes.
However, the post-war period sees not only some effects from the boosted salvage industry
stimulated by the demand for raw materials during the wars, but also increasing public
awareness of the environment.
1 956 – The Clean Air Act is passed signalling a decrease in the number of open fires in
homes as they are replaced by central heating fuelled by oil, gas or electricity. Consequently
the composition of household waste changes from being predominantly ash, dust and
cinder from fires, to being made up of other wastes such as food and paper which would
previously have been put on the fire.
1 960 – A working party set up by the Duke of Edinburgh criticizes the existing manage-
ment of the countryside and the environment, especially waste management. Its
recommendations lead to the setting up of the Royal Commission on Environmental
Pollution.
1 960s – Private waste contractors begin to take over in what had previously been consid-
ered a public works activity. In 1 968, contractors come together to form the National
Association of Waste Disposal Contractors.
1 05
1 970s – It takes a combination of increased new chemical waste, changing waste compo- 1
sitions after clean air legislation, and new health and safety guidelines to bring about the 2
first serious waste regulations during the 1 970s. This is also linked to concerns over 3
energy use and the wider depletion of resources. 4
5
1 971 – Some drums of cyanide waste are dumped at an abandoned brick kiln near
6
Nuneaton, leading to a huge public outcry. The ensuing furore, along with press coverage
7
of waste disposal drivers taking bribes to dump hazardous waste illegally, and a report
8
by the Royal Commission on toxic wastes, provides a catalyst for the first ever legisla-
9
tion to control hazardous waste. The consequent Deposit of Poisonous Waste Act 1 972
10
is drafted in 1 0 days and passed through Parliament within a month.
1
Friends of the Earth launches its first campaign by returning thousands of bottles to 2
Schweppes, an environmental stunt that successfully uses the media to bring issues of 3
waste and product disposability to public attention. 4
5
1 974 – Increasing concern over waste leads to the Control of Pollution Act 1 974, which
6
aims for a much wider control of waste disposal and regulation of sites, and begins a
7
serious tightening up of waste disposal methods.
8
9
1 977 – The first bottle banks appear in Britain.
20
1 980s – The decade sees increasing public concern over waste disposal, especially 1
hazardous waste. The construction boom results in an estimated 1 million tonnes of ille- 2
gally deposited waste lying around London at any one time. Those who produce the 3
waste have no responsibility for it. Directives from the European Union begin to put 4
pressure on the British government, and there are contentious issues such as the import 5
of wastes, contaminated land and inadequate powers of waste regulators. The increasing 6
number of private sector contractors in waste management begin to challenge the enforce- 7
ments and self-regulation of the local authorities. 8
9
1 986 – Environmental protection finally gets included in the Treaty of Rome through
30
the Single European Act.
1
1 987 – The National Council for Voluntary Organisations sets up a project called Waste 2
Watch to promote and support waste reduction, reuse and recycling. Over 1 5 years later, 3
Waste Watch is an independent national charity working alongside local authorities, com- 4
munity and voluntary groups, businesses, industry and government, providing advice, 5
training and information from the Wasteline, as well as practical support for action. 61
1 06
1 989 – The Commons Environment Committee inquiry, chaired by Sir Hugh Rossi,
recommends that waste regulation pass from local authorities to a central body.
1 990 – The Government produces ‘This Common Inheritance’, its first comprehensive
White Paper on the environment. This sets out a waste strategy that regards waste mini-
mization and recycling as priorities, and sets a target of 25% for the recycling of household
waste by 2000.
The subsequent Environmental Protection Act 1 990 separates waste regulation from oper-
ational work in local authorities and implements more regulations and controls. It
replaces the 1 974 Act with a new licensing system covering all controlled wastes (certain
household, commercial and industrial wastes) and requires local authorities to consider
recycling in their waste strategies.
1 992 – The ‘duty of care’ is introduced, whereby anyone who ‘imports, produces, carries,
keeps, treats or disposes of controlled waste’ must take responsibility for it. Those who
deal with waste are now given a duty to care for it, managing waste from its generation
through to transfer and disposal.
The Eco-labelling Scheme is set up to recognize relative environmental impacts of similar
products.
1 994 – An EU Directive introduces the idea of producer responsibility with regard to
packaging waste, requiring member states to set targets on the reduction and recovery
of packaging waste. This was followed by the UK’s Producer Responsibility Obligations
Section 93 (Packaging Waste) Regulations.
1 995 – The Environment Act establishes the Environment Agency, replacing the National
Rivers Authority, Her Majesty’s Inspectorate of Pollution, Waste Regulation Authorities
and some parts of the Department of the Environment. As a central body its aim is to
manage and regulate not only waste but also industrial pollution and water resources.
1 996 – The Government publishes its waste strategy for England and Wales, entitled
‘Making Waste Work’. This document sets out plans for sustainable management of waste,
and also confirms the target of 25% of household waste to be recycled by the year 2000.
The landfill tax is introduced, which levies £7 per tonne on active waste going to land-
fill in order to encourage alternatives such as reuse and recycling, and promote waste
1 07
minimization. The standard rate will increase to £1 0 per tonne from 1 April 1 999, with 1
a lower rate for inactive waste frozen at £2 per tonne. Inert waste used in the restora- 2
tion of landfill sites and quarries will be exempt from 1 October 1 999. 3
4
1 997 – The Producer Responsibility Obligations (Packaging Waste) are implemented,
5
requiring businesses to recover and recycle 38% of their packaging, increasing to 56%
6
by 2001 . There are also additional recycling targets to enforce a minimum percentage of
7
recycling for each of the packaging materials (currently paper and card, plastics,
8
aluminium, steel and glass) . The obligations are shared between raw material manufac-
9
turers, converters, packers and fillers, and sellers.
10
1
1 999 – The Government releases ‘A Way with Waste’, a draft waste strategy for England
2
and Wales updating ‘Making Waste Work’. The national waste strategy for Scotland is
3
also launched, with specific goals for reducing special and industrial waste arisings. In
4
the 1 999 budget the landfill tax is placed on a ‘landfill escalator’ of £1 per year until
5
2004.
6
7
2000 – A finalized waste strategy for England and Wales – ‘Waste Strategy 2000’ – is
8
published, setting revised national targets for the recycling or composting of household
9
waste: 25% by 2005, 30% by 201 0, and 33% by 201 5. The ‘Waste Management Strategy
20
for Northern Ireland’ is launched, setting targets for household waste similar to ‘Waste
1
Strategy 2000’.
2
2002 – The EU Regulation on Ozone Depleting Substances comes into force. Under this 3
regulation any insulation foam or cooling circuits containing CFCs or HCFCs must be 4
recovered from fridges and freezers prior to shredding and disposal. 5
6
‘Waste Not Want Not’, the Strategy Unit’s report on Waste Strategy 2000, is published.
7
8
2003 – The budget raises the landfill tax escalator to £3 per year from 2005.
9
30
The WEEE ( Waste Electrical and Electronic Directive) is implemented. England will have
1
to collect 4 kg of WEEE from every household by 2006.
2
61
1 08
Appendix 3:
Outline of legislative drivers for
waste management and likely
future impacts on business
Current European legislation
Waste Framework Directive (75/442/EEC)
• Original directive amended several times in the 1 990s and 2000, and most recently
in 2005 to cover definitions, BAT and IPPC, and impacts regarding the Hazardous
Waste and Waste Oils directives.
• System for the coordinated management of waste within the community.
• Foundation for sustainable waste management.
• Defines waste and introduces the principles of the waste hierarchy, proximity prin-
ciple and self-sufficiency.
• Potential for a review of Annex II: will impact upon recovery and disposal operations
defined in the Annex.
Landfill Directive (99/31 /EC) (implemented July 2001 )

• ‘To prevent or reduce as far as possible negative effects on the environment, in partic-
ular the pollution of surface water, groundwater, soil and air, and on the global
environment, including the greenhouse effect, as well as any resulting risk to human
health, from the landfilling of waste, during the whole life-cycle of the landfill’.
• Introduction of stringent technical requirements for waste and landfills.
• Ban on specific wastes (2003 whole tyres, 2006 shredded tyres, 2002 liquid hazardous
waste, plus other hazardous wastes) .
• Pre-treatment (2004 hazardous waste, 2007 all other wastes) and Landfill Allowance
Trading Scheme (LATS) .
• Targets for reduction of biodegradable waste (201 0, 201 3, 2020) .
Hazardous Waste Directive (91 /689/EEC) (implemented July 2005)

• Licensing requirements for handling and treatment of hazardous waste.
• Singles out specific waste materials as a consequence of their hazardous nature and
potential impact upon health and the environment.
• 1 January 2002: single list of hazardous waste established (added 200 to original list) ,
fully implemented from 1 6 July 2005.
1 09
• Extended range of hazardous waste materials listed beyond scope of UK Special Waste 1
Regulations. 2
3
Incineration of Waste (2000/76/EC) (implemented December 2002) 4
• Extended to cover co-incineration plants.

5
• Sets stricter limit values and technical requirements.

6
• New plants required to comply in 2002, existing plants by December 2005.

7
End-of-Life Vehicles Directive (2000/53/EC) (implemented April 2002) 9
10
• Waste prevention priority.
1
• Reduce the use of hazardous substances in vehicle design.
2
• Ease of dismantling, reuse, recovery and recycling of end-of-life vehicles a priority.
3
• Increase use of recycled materials in vehicle manufacture.
4
• Sets targets and deadlines.
5
Disposal of Waste Oil (75/439/EEC) 6
7
• Priority to processing of waste oils by regeneration (i.e. by refining) .
8
• Problems encountered with member states favouring combustion rather than refining.
9
Disposal of PCBs and PCTs (96/59/EC) (implemented March 1 998) 20
1
• Aims to dispose completely of PCBs and equipment containing PCBs as soon as
2
possible; for big equipment, deadline is end of 201 0.
3
• Member states required to keep an inventory of equipment containing PCBs and plan
4
for disposal plus outline plans for collection and disposal of non-inventoried equip-
5
ment.
6
7
Packaging and Packaging Waste Directive (94/62/EC)
8
• Producer responsibility legislation. 9
• Lays down essential requirements regarding the composition, reuse, recovery and recy- 30
cling of all packaging. 1
• New increased recovery and recycling targets for 2008. 2
3
Ozone Depleting Substances Regulations (in force from 1 January 2002)
4
• Disposal of units containing CFCs though specialist plants to ensure proper treat- 5
ment and disposal. 61
110
APPE N D I X 3. O U TLI N E FO R LEG I S LATI VE D RI VE RS FO R WASTE M AN AG E M E N T
Regulation on the Supervision and Control of Transfrontier Shipments

of Waste (259/93/EEC)
• System of supervision and control of all movements of waste.
EU Regulation on Waste Statistics (21 50/2002) (came into force 29

December 2002)
• Framework for the production of community statistics on the generation, recovery
and disposal of waste.
• Requires member states to provide statistics on generation, recovery and disposal of
waste.
• First year of collection is 2004, followed by every two years.
Current European legislation with revisions

proposed
Batteries & Accumulators Directive (91 /1 57/EEC)
• Currently under revision due to its limited scope.
• New proposals for collection and recycling targets and ban on batteries containing
mercury plus phase-out of cadmium by 2008.
Integrated Pollution Prevention and Control Directive (96/61 /EC)

(implemented 2000)
• Transition period until October 2007.
• Permit system, to prevent and control pollution arising.
• 2003 Commission reviewed compliance and found it to be insufficient.
• Revision could change thresholds that determine which installations require IPPC, or
inclusion of additional activities on the permitted list of installations.
Sewage Sludge Directive (86/227/EC)

• Revision intends to broaden scope to wider range of sludges and wider range of
receiving land types.
• Results in a diversion into other treatment or disposal options.
• Requires the development of more advanced technologies in the long term.
111
The Waste Electrical and Electronic Equipment Directive (2002/96/EC 1
and 2003/1 08/EC) 2
3
• Producer responsibility legislation.
4
• Prevent generation, and promote reuse, recycling and other forms of recovery.
• Restrict the use of hazardous substances in electrical and electronic equipment.

5
• Minimize disposal of WEEE as unsorted Municipal Solid Waste (MSW) and set up
6
7
collection system.
• Targets and deadlines set in place from 2005 in terms of collection systems (now June
8
9
2006) , and 2006 for rates of separation, recovery and recycling. The Directive will be
10
fully in force from July 2007.
1
ROH S Directive (2002/95/EC) (implemented 1 3 August 2004) 2
• Restrictions posed on new electrical and electronic equipment in terms of banning 3
specified hazardous components. 4
• Target date of 1 July 2006 for new electronic and electrical equipment. 5
6
Directive Providing for Public Participation in Development of Plans 7
and Programmes (2003/35/EC) (implemented June 2005) 8
• To ensure and improve public participation. 9
• Specific waste directives listed as falling within the scope of this directive. 20
1
Strategic Environmental Assessment Directive (2001 /42/EC)
2
(implemented 2004)
3
• Ensure that environmental consequences of plans and programmes are identified and 4
taken into account during preparation and before adoption. 5
• Waste management planning covered by the directive. 6
7
Proposed European legislation 8
9
Proposed Biowaste Directive (now cancelled) 30
• Aimed to provide a strategic approach to the management of biowaste, influence the 1
acceptability of management practices of biodegradable wastes by imposing controls 2
on facility operation and end uses, cover MSW and biodegradable residues from a 3
wide range of processing industries and possibly require that separate collections be 4
enforced to maximize the scope for composting and anaerobic digestion – now 5
subsumed into the Landfill Directive. 61
112
Proposed Management of Waste from Extraction Industries Directive

• Applies to waste resulting from extraction, processing and storage of mineral resources
and the working of quarries.
• Provisions are directed at the management of waste facilities.
• Minimum supplementary standards are laid down with a proposal that BAT be used.
Proposed Framework for the Setting of Eco-design Requirements for

Energy-using Products Directive
• Looks to set requirements for environmentally relevant product characteristics on a
life-cycle basis.
• Focuses on traded goods not covered by other policy or legislation.
• Works in synergy with other EU legislation.
Thematic strategies
The 6th Environment Action Programme: Environment 201 0: Our
Future, Our Choice
• Framework for current and future EU policy and legislation.
• Development of Thematic Strategies for seven key environmental issues.
• Focused on waste prevention; waste recycling; turning waste into a ‘greenhouse neutral’
energy source; optimizing final disposal of waste.
• Specific target: reduce quantity going to final disposal by 20% by 201 0 and 50% by
2050.
Towards a Thematic Strategy for Soil Protection (communication

published April 2002, strategy due 2004/2005)
• Revision to Sewage Sludge Directive (reducing maximum permitted levels of conta-
minants in sludge, plus extending this to all land where it is applied) .
• Proposal for a directive on compost and other biowaste by end of 2004.
• Sets objectives and measures related to composting.
Towards a Thematic Strategy on the Sustainable Use of Natural

Resources (communication published 2003, implementation 2005)
• Policy measures to reduce resource consumption.
113
• Decoupling is overarching goal – a long-term process, therefore timescale of the 1
strategy will be 25 years. 2
• Addressing demand issues and improving resource efficiency. 3
• Improving recycling rates. 4
• Green procurement. 5
• Three strategic elements: knowledge gathering, policy assessment, policy integration. 6
• The strategy will set the framework for Integrated Product Policy (IPP) . 7
8
Towards a Thematic Strategy on Recycling and Prevention of Waste 9
(full strategy proposed December 2005)) 10
• Development of waste prevention and waste recycling targets. 1
• Mix of voluntary, regulatory and economic instruments: prevention plans, low-waste. 2
• Production techniques, best practice, direct/variable charging mechanisms, bans, 3
producer responsibility, standards. 4
• Promotion of research and development for waste prevention and resource-efficient 5
processes. 6
• Increasing demand for recycled materials. 7
• Integration of environmental concerns into education and training. 8
• Future policy based on fuller scientific analysis. 9
• Simplify and improve implementation of waste legislation. 20
Towards a Thematic Strategy on the Urban Environment (launched 2
January 2006) 3
• Four cross-cutting themes:

4
5
o sustainable urban management (which of course includes waste) – use of LA21 ,
6
EMAS;
7
o sustainable urban transport;
8
o sustainable construction (resource use, design issues, performance-based approach
9
etc.) ;
30
o sustainable urban design.
• Framework for local, regional, and national actions to promote each theme.
1
61
114
Other
Green Paper on the Environmental Issues of PVC (July 2000)
• Review of the environmental and health effects of PVC waste.
• Criticized for a lack of life-cycle analysis of PVC products to allow comparison with
alternative materials.
• Draft long-term horizontal strategy on replacement of PVC called for, plus labelling
system.
• Recycling system similar to that for end-of-life vehicles and bans on lead and cadmium.
Integrated Product Policy (communication launched June 2003)

• Strategy to stimulate greener products.
• Designed to work with Thematic Strategy on Sustainable Use of Natural Resources,
and Thematic Strategy on Recycling and Prevention of Waste.
REACH (Chemicals – currently being voted on in EU)

• Proposal for a new regulatory framework for chemicals.
• Greater responsibility to industry to manage risks from chemicals and improve protec-
tion of human health and the environment.
• Registration system, plus authorization required for use of some high-risk substances.
First Environment Policy Review

• Identified resource management priorities.
• Intensify efforts towards more sustainable use of resources.
• Ensure proper implementation of existing waste legislation – commission to screen
waste legislation in 2004 with a view to simplification.
• Renewed approach to environmental policy, plus awareness of international challenges
for environment policy.
• Benchmarking and peer review between member states.
• Environment Technology Action Plan.
• REACH system.
• Use of market-based instruments for environmental policy – communication planned
for 29 February 2004 adoption of Environmental Liability Directive.
115
National drivers 1
3
Waste Strategies for England, Northern Ireland, Scotland and Wales
4
• Set targets and deadlines.
5
• Focus mainly on MSW in terms of targets.
6
• Reflect sustainable policy.
7
8
U K Sustainable Development Strategy
9
• Overarching strategy for sustainable development.
10
• Underpins policy development.
1
• Tackling waste one of seven key priorities for the future.
2
• Headline indicators include waste.
3
4
Special/Hazardous Waste Regulations
5
• Now updated to take into consideration the changes to the Hazardous Waste List. 6
• Changes emphasis from waste managers to waste producers; registration of waste 7
producers. 8
9
Producer Responsibility Obligations (Packaging Waste) Regulations
20
1 997
1
• Implement the packaging directive. 2
• Slow progress in the UK to date. 3
• Failures in meeting targets. 4
5
Agricultural Waste – Waste Management Controls
6
• Public consultation 2004 on extension of waste controls to include agricultural waste 7
apply from 2005. 8
• Uncontrolled burying or burning of agricultural waste on farms prohibited. 9
30
Household Waste Recycling Bill 1
• By 201 0 all households have a collection of at least two recyclates separate from the 2
remainder of the waste. 3
• Duty is placed on English waste collection authorities. 4
• The aim of the bill is to increase the recycling rate, which currently stands at 1 7.7%, 5
by helping local authorities achieve their statutory recycling targets, which underpin 61
116
national targets to recycle or compost at least 25% of household waste by 2005, 30%
by 201 0 and 33% by 201 5.
Waste Not Want Not, Prime Minister’s Strategy Unit, November 2002
• Main focus is MSW and Landfill Directive requirements.
• Identifies priority areas and makes recommendations for action.
• Targets waste growth, improving data and research, and raising awareness.
• Success measures for the strategy include reducing waste growth to 2% per year by
2006; 50% of households carrying out home composting by 2006; rollout of kerbside
collection; higher recycling and/or composting targets; 30% of collection authorities
to have tried incentive-based schemes by 2005/6.
Making More with Less, Prime Minister’s Strategy Unit, November

2001
• Targets for long-term improvements in resource productivity and reductions in waste
and pollution.
• Development of economic instruments to improve resource productivity.
• Sustainable development at the core of procurement policies.
• Encourages corporate social responsibility.
Best Value Performance Indicators (BVPIs)

• The duty of continuous improvement for local authorities as set by the Local
Government Act 1 999.
• Indicates performance of local authority in a range of different sectors, including
waste management.
• Focus of BVPIs reflect the focus of the national waste strategies
• Drives local authorities’ efforts in recycling and composting, as performance is
compared to others.
Landfill Tax
• Aims to encourage waste producers to produce less waste, recover more value from
waste, and divert more waste from disposal.
• Currently at £2 per tonne for inert waste e.g. rocks and soil, and £1 8 per tonne for
all other landfilled waste.
• Will increase by a minimum of £3 thereafter towards a target of £35 per tonne by
201 0.
117
Aggregates Levy 1
2
• Came into effect 1 April 2002.
3
• Aims to address the environmental costs associated with quarrying operations, reduce
4
demand for aggregate and encourage the use of alternative materials where possible.
5
• £1 .60 per tonne.
6
• Sustainability Fund Grant Scheme, currently being reviewed for 2006.
7
Waste and Emissions Trading Bill 8
9
• Landfill allowance scheme to reduce amount of biodegradable municipal waste going
10
to landfill.
1
• Intends to support UK in meeting Landfill Directive targets.
2
• Waste disposal authorities will be able to bank, borrow or transfer allowances.
3
Framework for Sustainable Consumption and Production 4
5
• Provides the direction for the government to take forward sustainable consumption
6
and production.
7
• Focuses on decoupling economic growth and environmental degradation: decoupling
8
indicators for waste and resources.
9
• Increases the productivity of material and energy use.
20
• Promotes the corporate consumer practising more sustainable consumption.
1
• Life-cycle analysis of products and services.
2
Local delivery 4
6
Commercial opportunities
7
• Private Finance Initiatives & Public Private Partnerships. 8
• Technological developments. 9
• Market advantages. 30
• Diversification. 1
2
Public behaviour 3
• Consumer needs and demands. 4
• Availability of choices. 5
• Acceptability, opportunity and role. 61
118
Waste growth
• Reliability of data on waste growth: Municipal Solid Waste, Commercial and Industrial
Waste, Construction and Demolition Waste.
• Targets to reduce waste growth in Waste Not Want Not.
• Decoupling of economic growth with waste growth.
• Producers and consumers – relationship and conflicts.
119
1
10
20
30
61
Appendix 4:
Case study solutions for
Chapter 6 11
Outline a case for integrating environmental and health and safety management within a
company such as your own.
Solution
This should include elements such as the following.
• A well-planned integrated management system (IMS) is likely to operate more cost-
effectively than separate systems, and facilitate decision-making that best reflects the
overall needs of the organization.
• An IMS offers the prospect of more rewarding career opportunities for specialists in
each discipline.
• The objectives and processes of management systems are essentially the same.
• Integration should reduce duplication, for example in personnel, meetings, comput-
erized record-keeping software, audits and paperwork.
• Integration should reduce the possibility of resolving problems at the expense of
creating new difficulties in other disciplines.
• Existing quality task procedures may be developed more easily within an IMS to incor-
porate the needs of health and safety and environmental performance, and there would
be greater certainty that the procedures properly incorporated these needs.
• An IMS should involve timely overall system reviews where momentum in one element
of an IMS may drive forward other elements that might otherwise become moribund.
In contrast, independent systems could develop without regard to other management
system elements leading to increasing incompatibility.
• Expertise in each discipline could be more readily brought together to address specific
issues. This would promote the exchange of fruitful initiatives (e.g. attitude surveys)
and techniques (e.g. risk assessment and problem-solving methodologies) between
the disciplines. Moreover, all the specialists, working together, are likely to arrive at
optimum solutions that take fully into account the needs of each discipline.
1 1 Adapted from Open University – T835, Integrated Safety, Health & Environmental Management 2003.
1 21
• The IMS may be more readily linked with management arrangements for other 1
purposes, e.g. product safety and security – in cases where these are not already part 2
of an IMS. 3
• An IMS should minimize distortions in resource allocations in separate systems asso- 4
ciated with: 5
o a determination to retain current priorities, despite contrary evidence; 6
o personnel responsible for one management system being more effective champions 7
8
of their discipline; and
9
o variations in the immediacy and precision of feedback; for example, quality assur-
10
ance feedback is usually rapid and statistically reliable, whereas there may be a time
1
delay of several years before an organization has statistically significant evidence
2
of the effectiveness of an OSH initiative.
3
• A positive culture in one function may usefully be carried over to the others.
4
What arguments might there be against integration? 5
6
• The existing systems may simply work well. The process of integration may threaten
7
the coherence and consistency of current arrangements that have the support of
8
everyone involved.
9
• Relevant specialists may continue to concentrate on the area of their core expertise
20
and further specialist training may not be needed.
1
• The models on which each management system is based may appear compatible, but
2
there are conceptual differences that may be difficult to reconcile. For example, quality
3
audits assess compliance with a system standard, however deficient, whereas health
4
and safety audit should evaluate effectiveness, as well as compliance. Furthermore,
5
uncertainties regarding the meaning of key terms – already a problem in health and 6
safety – would be exacerbated in an IMS. 7
• An IMS could become over-centralized and over-complex without the capacity to give 8
sufficient consideration of local needs and constraints. Already many employers and 9
employees are sceptical of the excessive bureaucracy of existing management systems. 30
• The time during which an organization is planning and implementing an integrated 1
system is a period of organizational vulnerability. Existing procedures may lapse, or 2
be found wanting, at the moment when key personnel are focusing attention on the 3
development of new systems. 4
• System requirements may vary across the topics covered, e.g. an organization may 5
require a simple quality system, but a more complex health and safety or environ- 61
1 22
APPE N D I X 4. CAS E STU DY S O LU TI O N S FO R CH APTE R 6
mental performance system. The IMS could introduce unreasonable bureaucracy into,
in this case, quality management.
• There may be distortions in IMS coherence because:
o BS EN ISO environmental performance and quality standards are certificatible, but
the BS guide to occupational health and safety management is not; and
o health and safety and environmental performance are underpinned by statute, but
quality management system requirements are largely determined by customer spec-
ification;
o professional/organizational rivalries may impair the collective operation of the
system. Typically, a senior quality manager might seek to impose quality audit
obj ectives on a more j unior health and safety team. In contrast, the quality manage-
ment team might resent supervision by an environmental manager who lacks an
intimate knowledge of quality control statistical techniques;
o regulators and single- topic auditors may have difficulty evaluating their part of the
IMS when it is ( quite properly) interwoven with other parts of no concern to the
evaluator;
o the work of external consultations may be impaired because the needs of business
confidentiality could prevent them taking a rounded view of elements of the IMS;
o a powerful integrated team may reduce the ownership of the topics by line manage-
ment; and
o a negative culture in one topic may unwittingly be carried over to the others.
What issues might influence the setting of priorities for action when
implementing an integrated management system?
The issues that may influence the setting of priorities are likely to include legal pres-
sures, ‘image’ issues, stakeholder interests including customer pressures, corporate/parent
company influences, and neighbours.
1 23
BIP 21 02
B SI Th e O p e n U n i ve rsi ty
G ro u p H e a d q u a rte rs Wa l to n Hall
3 8 9 Ch i swi ck H i g h Ro a d M i l to n Ke yn e s
Lo n d o n W4 4AL M K7 6 AA
www. b s i -g l o b a l . co m www. o p e n . a c. u k
Th e B ri ti sh S ta n d a rd s I n sti tu ti o n
i s i n co rp o ra te d b y Ro ya l Ch a rte r

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E N V I R O N M E N TA L M A N A G E M E N T R E P O R T

Focus on Waste Management

Mark Yoxon, Stephen Burnley

© The Open University 2006 8

ISBN 0-580-4841 2-2 1

Typeset in Akzidenz Grotesk and Minion by 4

1 Introduction to the report 1

Some examples of cost savings 2

Some examples of ﬁnes and prosecutions 3

Beneﬁts of waste management 5

Identifying waste in the workplace 9

How much waste do we produce? 13

3 Why bother with waste? 17

Keeping on the right side of the law 20

The ﬁnancial drive 22

What should I do with my waste? 29

4 How to manage waste 31

What is effective waste management? 32

A waste review – the seven steps to effective waste management 34

5 An introduction to key waste legislation 49

Background – who are the regulators? 49

The Landﬁll Directive 56 1

The Environmental Protection Act and Duty of Care 57 2

6 Waste management in relation to other management systems 67 8

Why integrate waste management with other management systems? 68 1

8 Gateways to help and support 89 7

Other useful contacts 91 1

1 Checklists for waste review 93 4

2 History of waste and recycling 1 01 5

3 Outline of legislative drivers for waste management and likely 6

future impacts on business 1 09 7

4 Case study solutions for Chapter 6 1 21 8

and adds up to measurable beneﬁt.

• A whole raft of stakeholders, from banks and insurance companies to non-govern-

that business improves its environmental performance. Alongside energy manage-

changes to operational procedures. It is a surprise that so often it is a missed opportu-

beneﬁts of effective waste management.

equals business beneﬁt.

contribute to lost proﬁts.

happening and to develop organizational intelligence on what causes waste, where it is 2

Chapter 8 is intended to provide authoritative sources of help and advice. 5

efﬁciency. We include practical solutions, tools and techniques to demonstrate and

than the environment.

management. The answers add up to an effective waste management strategy for

Key q u esti on s An swers – Ch a pters:

Wh at are th e b e n e ﬁ ts o f e ffe cti ve wast e m an ag e m e n t ? 3 & 2

H ow do I st art to m ake s e n se of was t e m an ag e m e n t ? 3 & 5

H ow can I d e ve l o p a wast e m an ag e m e n t s trat e g y? 5

H ow do I m ake se n se o f was t e l e g i s l ati o n ? 6, 4 & 8

Wh y an d h ow do I i n t e g rat e wast e m an ag e m e n t wi t h 4 & 5

Wh at can I l e arn fro m o t h e rs ? 8 & Al l

Examples of ﬁnes and

in more detail in the report.

All forward-looking organizations have resource management ﬁrmly on the business 1

agenda and ask questions such as: 2

• how do you procure materials and services? 6

• how do you use raw materials in the business? 7

• how do you utilize transport and distribution in the business? 8

Organizations can ‘hide’ waste under a multitude of euphemisms, but we need to

be honest and recognize waste in all its forms.

2.1 Waste in general

a few of your thoughts.

ness carries out and your role in the organization. 2