People are starting to question how it might be properly implemented and enforced, quite reasonable questions, I would say!
Currently it seems to be struggling for recognition, for the important element of regulation that it is. The Waste Hierarchy is a mainstay of the prime objectives of the Environmental Action Plan and for sustainability in the waste and resource management sector.
There are a number of reasons for this, not least that the Waste Hierarchy is seen as being self regulating, however a lesson learnt from a very similar roll out of the Duty of Care over 20 years ago, informs us that this wasn't entirely successful!
There are also a number of other reasons why it been difficult to implement, I have outlined some of these below. The solutions to these are not particularly simple, but could be tackled with a proper strategy and some resource.
Briefly these area:
- Current behaviours in C & I waste collection, whereby the contractors take on all the responsibility (or maybe not). This is mainly why the tick box exists on the DoC WTN.
- Lack of clear policy on waste planning. In turn this leads to lack of, or inappropriate investment in handling and treatment technologies. Most of the money is currently following EfW because of the potential for ROC's/RHI, this conflicts with the Waste Hierarchy to some extent.
- Slow drafting and implementation of End of Waste criteria is hampering the the quality assurance that is needed to underpin recyclate markets. Volatility leads to more waste being exported (often illegally), incinerated or landfilled.
- Similar (or better) incentives need to be put in place to encourage re-use.
- Waste reduction, and avoidance needs clear policy leads and should sit with one department and have a much higher profile than it has currently
All companies with Environmental Management Systems should now be looking at how they can comply with the requirements of the Waste Hierarchy and it should become a regular feature of CSR reporting, that would be a start!