Summary of Key Strategic Issues to inform the NWMS

PACSA wishes to express its appreciation and satisfaction at the professionalism of the process and the very high quality of the research documentation and input. This opinion is shared by our Consultant based in London who is an international expert on packaging waste legislation and solutions.
In general we are in agreement with the broad issues and our comments will thus tend to be of detail. We will deal with the issues in the sequence of the report.

1. Table 1.1 under Domestic and Commercial general waste we believe that the inclusion of “Separation at source of household waste” is a key strategic challenge that needs to be included .We will refer to this issue later.
2. Section 3 – Overall strategy. The Polokwane Declaration has been referred to in the research papers and is considered by most to be unrealistic as it is currently written. Perhaps a solution would be to give some meat to the Declaration by defining what zero waste means.
   To illustrate, we quote the Scottish example where that country has a zero waste policy and then it goes on to define:
   “Zero Waste does not mean that waste disappears. Instead it means eliminating the unnecessary use of raw materials, sustainable design, resource efficiency and waste prevention; re-using products where possible; and recovering value from products when they reach the end of their lives through either recycling, composting or energy recovery, in accordance with the waste hierarchy”
3. Section 3.1 – we fully support the overall approach but would like to add in the paragraph on  a tiered and consensual  model that with  Government support voluntary Industry driven initiatives should be expanded to include all players in that particular industry so that free riders  both  local  and imports are eliminated.
4. Section 3.1 The paragraph on Industry waste management plans in this section refers. As you are aware the Department has initiated discussion on the content of industry waste management plans. We have responded to these proposals and wish to comment that the proposals are far too detailed for a very complex Industry such as packaging and paper. We trust that the strategy would allow the flexibility for the Plans to be appropriate for the diversity and structures of the industry.This comment s also relevant for section 4,4.
5. Section 3 –Incorporating waste reduction principles into the design and packaging of products at the point of manufacture. We agree with this statement but submit that the search for lightweighting of packaging without compromising the performance of the packaging is already  part of normal commercial life, because it makes both commercial and environmental sense .
6. Section 3 –bullet point on percentage of recycling in products. We suggest a way forward would be to form working groups with Industry and Government to highlight those products where the impact would be the greatest. Public sector procurement for these identified products would be an excellent start.
7. Section 3 – separation at source at households. We need to be clear that this model is central to our achieving increased volumes of waste for the packaging and paper industries as the current method of collection from landfills is inefficient. The Plan for our industry will be unable to deliver more waste volumes without a cost efficient household separation model. The programme will create jobs as it has done elsewhere in the world , in the collection, sorting and recycling sectors.
8. Section 3 -Proven energy from waste technologies. At the current electricity tariff structures which are  low by world standards, it may prove difficult to provide a viable energy from waste alternative. The assistance of NERSA to consider a different tariff structure such as wind power is a possible solution.
9. Section 4.1 Norms and standards. We are very happy with the involvement of DTI in the process but urge that the formation of bodies such as the proposed Recycling Industry Body follow the approval of the NWMS so that we are not all overwhelmed by different committees doing the same things.
10. Section 4.2 Classification of waste. We believe there may be some concerns on the proposed classification from the paper industry and request that their views are represented.
11. Section 4.3 Waste Information system. It is accepted that SAWIS will take some time before accurate and reliable information is forthcoming. We strongly suggest that in the interim, data can be supplied by Industry Associations and some of this data is accurate. This will ensure the processes are not unduly delayed.
12. Section 4.7 Producer responsibility. To correct a perception, the packaging and paper responsibility schemes are voluntary but are not all exclusively based on post consumer waste streams. A varying  but generally meaningful proportion of their recoveries are also from commercial and industrial waste streams which are equally important as they could also end in landfill if not dealt with.
13. Section4.8 . Consumer protection – this needs further debate . Current comment and theory suggests that product  price needs to include the full life cycle costs.

Thank you
Andrew Marthinusen
Executive Director
PACSA
23 October 2009