Memorandum by Bob Lisney OBE, Director,
LRL Consultancy Services Ltd and Martin Charter, Director, Centre
for Sustainable Design
THE "WASTE"
HIERARCHY
1. It has become a mantra that at the top
of the waste hierarchy is "reduction". In various interpretations
of the term the words, "minimisation", "prevention"
and "avoidance" are also used, sometimes interchangeably.
2. For this submission we suggest that there
is a need for a hierarchy for reduction which we feel should be
adopted for general use in order to clarify terms in regular use.
DESIGN AND
INNOVATION
3. Objectives sought should be wider than
consideration of the materials in products. This stage should
consider whole life impacts including the use phase especially
in relation to energy (carbon) and end of life recovery. The incorporation
of environmental considerations into product development and design
(ref ISOTR14062) should be become integrated into the product
creation process. For example, Philips have six focal areas of
eco-design and implement them throughout the lifecyclepackaging
reduction, material reduction, longevity, increased recyclability,
energy reduction and substitution of hazardous chemicals.
4. Innovation is required at this level
to take advantage of materials technology development, but also
of product stewardship taking into account the opportunity to
"own" the product during its use phase and recover it
fully as a result of take back schemes. For example, "design
for remanufacturing" (DfReman), is in fact a strategic concept
that includes "design for closed loops" eg to effectively
implement DfReman requires investment in remanufacturing factories
eg Xerox, as well as thinking at the "front of pipe".[8]
There are lessons to be learned from the Japanese "system
innovation" related to resource productivity.[9]
Examples already demonstrate how widespread this service; including
vehicles, carpets, furniture, mobile phones, ink cartridges, and
could extend to a much wider range of products. The outcome sought
is a new business relationship with companies that better marry
together the functions of design and marketing, yet still retain
price competitiveness. A number of examples exist of how companies
are shifting to offering the service rather than the physical
products eg this is variously known as functional sales, product-service-systems,
or servicing.[10]
However, we need to widen our thinking to explore
the innovation system from ideas, through R&D to commercialisation.
Design is one part in the system and to enable "eco-innovation"
requires all elements to come together eg entrepreneurs, investors,
technology suppliers, inventors, etc.[11]
5. The above comments apply to manufactured
products. In addition to the product itself, similar consideration
is regularly given to packaging although packaging is often highlighted
as one area where there can be reduction. Inevitably improvements
will be made but the issue should always be to look at the role
of the packaging to see if it is fit for purpose as well as for
recovery.
CONSUMPTION
6. Business and domestic behaviour is the
driver behind patterns of consumption induced by effective marketing
of products.[12]
Consumption of goods is determined by many factors of which the
most important are economic and population growth. These two predominant
factors have the biggest impact on material use.[13]
More sustainable approaches to consumption and
production need to be implemented. There is growing focus on the
environmental impacts of consumption and the EIPRO study highlighted
three key sectors: housing; food; and travel. The EC's SCP Action
Plan is likely to pickup on these areas.
7. Assuming that goods are produced with
the right materials, using the necessary amount and all resource
efficiency has been achieved upstream, the consumer has two impacts
it can make on waste. Firstly, if a product is under a stewardship
or regulatory regime and can be wholly recovered, the material
is not "waste" but a secondary raw material or component
part for reuse. The domestic system of recovery has to be economic
and return material to market quality.
8. Should we worry then if consumption increases?
We want a healthy growing economy and if there is little or no
wastage then we shall have effectively decoupled economic growth
from resource usea major goal sought by the EU. However,
we use our national statistics to count this process as "waste".
9. We would recommend a change to the "waste"
strategy so that this element of statistical accounting is established
with those government departments say for Customs and Excise,
Business and Regulation so the figures have a meaning and a business
focus and on which better resource use policies may be made.
10. Targets can still be set for business
for recycled materials. A different way of accounting should be
applied.
11. The areas where increased consumption
can lead to more waste lie within internal business cultures and
in domestic demand.
12. For businesses, despite the good work
of Envirowise and government publications of ways to reduce consumption,
waste and costs, it has not been economic to focus on material
reduction. Big figure cost reductions are not available or commensurate
to the investment in making modest savings to the majority of
the UK's businesses which are SME's. As energy costs increase,
as regulations bite and as fiscal measures like the landfill tax
increase in impact, behaviour will change as it will become important
for these companies to focus on their wastage as it will have
a greater impact on the bottom line than now. The knowledge of
how to reduce all types of wastage including materials is widely
available on many web sites, government leaflets and via NGO environmental
groups and is increasingly available in articles in business journals.
Most regions also have green business "angels" or sustainable
business enterprises. There is thus no reason for organisations
not to know what to do. Response is slow only due to the external
conditions which have not hit them hard enough yet, however, there
is a need to make sure the message to SMEs is put in business
rather than environmental language. Awareness and knowledge of
eco-design amongst is still effectively at zero in the UKthis
means possible future compliance challenges, as well as missed
opportunities for innovation eg eco-design as a mechanism to simply
produce better products.
13. For the consumer it is a different task.
Technology changes mean greater need to change, for example, consumer
electronics and electrical goods, especially to derive cost and
energy reduction benefits. Fashion changes rapidly leading to
discard of goods which exceed the opportunity of reuse outlets
to deal with.
14. Food is probably the greatest area where
there can be reductions in waste. This relates to the use of organic
material, farm products from home or aboard which use resources
like feed, fertilisers, pesticides and water.
15. Defra in its recent review Waste
Strategy 2000 for England has urged the separate collection
of food and its treatment for compost type output material. This
seems to be the wrong way of looking at the issue of resource
management as it starts from the bottom upwards, at the bottom
of the current so called "waste" hierarchy.
16. If food accounts for some 20-24 per
cent of the dustbin, and dustbin volumes increase by 1-2 per cent
per year, it would seem important to focus on something which
is not only a reasonable volume but also has a negative environmental
impact if landfilled. We should also consider the input volumes
of material and other ingredients that go into producing the food
which is wasted to see if there is potential to reduce the total
system.
17. Current domestic reduction actions too
often focus on high profile but low volume items like carrier
bags and nappies with the generic heading of packaging coming
under regular attack. Most of the country's activities which attract
a substantial cost for no ability to improve impact, focus on
activities which are really reuse and recycling.
18. It would be better to focus on reducing
the food waste by 50 per cent. This would reduce the dustbin size
by 10 per cent and allow for some 5-10 years growth to be subsumed.
It would save householders some £200+ per year, far more
than any recycling incentive schemes might produce. There would
also be upstream savings in resource use in the production process.
19. This action would have an impact on
the recycling levels achieved by local authorities (unless their
targets were changed), the collection systems that have been encouraged
to be implemented, and the potential sizing and siting of processing
plants which would be built expecting a certain throughput.
20. We would encourage a multi-agency approach
to food waste consumption and reduction. Food consumption more
than is needed is creating a health problem of obesity, which
has a cost to the nation and also will require more material resources
to look after people, and its general waste is really a moral
and ethical issuewhich is about how a developed nation
uses world resources in an unequal way. So this is a matter for
a wide range of government departments working together holistically,
and not solely for Defra as part of a waste strategy.
Is waste an evil and should the aim be to reduce
it?
21. We need to reduce resource use for its
environmental damage during its excavation and process modes.
It is also at those early stages that hazardous, scarce and expensive
materials can be removed from inclusion in products.
22. Once products have been purchased they
will become known as "waste" when the consumer discards
them. Our attitudes and behaviours have been changing in the last
20 years and will continue to change so that what we currently
count as "waste" will in the future be seen to be part
of a recovery system. Assuming that 60 per cent average of all
materials can be recycled practically, then "waste"
from treatment will be 40 per cent of current figures.
23. If this amount requiring treatment is
used for energy production more can be extracted from its inherent
properties. Energy, a public utility which we now need for security
and cost reasons as well as the ability to contribute to carbon
reduction is produced, and also as a by-productresidues
which can have further use to displace construction materialas
well as the recycling of as much metal as is collected from conventional
recycling schemes. Such material is not allowed to count in the
recycling figures and so distorts real material utilisation mass
balances.
24. So should our aim be to count waste
that is landfilled as being our true target for reduction? If
so we would not wish to default to the next immediate element
of the current hierarchy, energy recovery, but to develop a set
of business and total system principles which take a top down
approach, so that optimum resource use can be derived throughout
the cycle of (sustainable) consumption and production (SCP). It
may be that we can accept more tonnage being recycled than now,
even if the percentage levels we currently manage are reduced
because we have a more effective total resource management system.
It is not a de facto right that reuse is better than recycling,
slavish adherence to a hierarchy that does not relate to business
or societal principles seems to mislead policy.
Is a focus on waste reduction the right way of
asking the question?
25. We believe the focus should be on ensuring
that there is an effective utilisation of resources through society.
There is a need for a major investment in primary, through secondary,
tertiary and higher education, in the benefits of a eco-design
and lifecycle approach including material and energy reduction
strategies. This should be built into design, engineering, technology
and architecture courses. A key target will be to bring the Deans
and Heads of Departments of appropriate courses together.
26. A top down focus achieves more energy
spent on the critical elements of design and material choice.
But there will not be any figures produced for this, so it will
be difficult to prove resource optimisation. Successful companies
may well reduce the unit costs of their product by careful choice
and good production methods but use more resources as a result
of selling more goods.
27. It is only when goods are produced and
can be weighed that it is possible to trace the best resource
routes and if as we argue, the new system is about recovery and
not waste, then we should take away from the waste statistics
those which relate to material recovery.
28. There is a view that a better statistic
is the use of kilograms per household or person per year of both
recycling and waste. This allows a comparative study over time
of whether there is real waste reduction on a per capita basis.
It is population growth that distorts aggregated figures such
as total volumes. Nevertheless this is the task that has to be
managed. So setting total waste reduction targets without taking
into account population growth creates a challenge that may lead
to non fulfilment.
29. The OECD highlights that waste growth
will rise in the next 20 years but these figures are based on
expected resource use and population growth. This leads to a recognition
that we are dealing with two paradigms one relating to a macro
level societal development and the other micro level targets to
create change in behaviour.
CONCLUSION
The outcomes of our analysis are that we need:
To recognise that we live, work and
do business in a global sustainable consumption and production
system eg UK is not a closed system (therefore we need to co-operate
with key players in the chains and networks eg US, China);
A top down approach coupled with
incentives on the ground;
Smarter and joined up product policy
eg how can public procurement be used to drive innovation and
reduced environment impact (zero waste mattresses should be viewed
as just a start and not as a tick the box exercise);
A focus on a sustainable society
that values resource use in a looped system;
A review of our policy approach to
a hierarchy for the subject;
Encouragement for designers to work
closely with marketing departments of organisations;
Develop eco-innovation systems involving
all appropriate stakeholders (avoiding "silo thinking");
Closer working on the issues between
the former DTI and Defra;
International co-operation eg build
on Anglo-Japanese initiative (we should learn lessons from those
who have been more successful);
Sensible statistics and national
performance targets based on total environmental assessments;
To overcome the confusion in the
use of terms and also the solutions eg minimisation, prevention,
reuse and recycling confused with reduction;
and also:
Need to look at the system and broaden
thinking from design to innovation;
Explore the reasons why the Sustainable
Design Forum and the Product Body failed to happenthere
is perhaps a need for a new body to take the strategic thinking
(and implementation) forward eg WRAP is not there, the Design
Council don't want the issue, etc;
Need for smarter policy;
8 see "Design for Remanufacturing" report
on www.cfsd.org.uk Back
9
see www.cfsd.org.uk and report on "information" pages
on www.cfsd.org.uk/aede Back
10
see www.suspronet.org Back
11
see "Sustainable Innovation" report on www.cfsd.org.uk
and also www.cfsd.org.uk/eco-i-net Back
12
see www.cfsd.org.uk/smart-know-net Back
13
see www.score-network.org Back
|