Waste Audit Trails – Time For Waste Legislation Change?
Should be compulsory for waste operators to provide detailed information about how they dispose of the waste that is collected?
Waste audit trails – or the ability of producers of waste to show a clear audit trail linking the waste they create to where it ended up and how much avoided landfill – are definitely rising in popularity in the waste industry. Perhaps not surprisingly, I’m a huge fan.
In terms of waste audit trails at AnyJunk – we load and record removed waste (we even have onboard weighing to ensure we get the tonnages correct) and we link it through to the end transfer station or recycling facility to which it is taken. As such, I look forward to the day when waste regulation (backed by strict enforcement) will make it impossible to remove waste without not only providing detailed information about what the waste comprised but also a waste disposal report linking back to where it was disposed and how much was recycled.
However, at present, there is no legal obligation for producers or collectors of waste to provide any sort of waste audit trail. Instead, there are various initiatives – particularly from within the construction sector (driven by the introduction of site waste management plans and looming targets for landfill diversion) and also CSR departments – that are pushing waste companies to provide better information on the material breakdown of their client’s waste and greater clarity on how much is being recycled.
At present, this trend appears to be favouring waste companies with their own processing facilities, particularly those with good landfill diversion stats for their sites. The theory being that if the company that provides the skip or bin is the same as the one that processes the waste, they should be best placed to know what the waste was and where it ended up. They can, therefore, report back with good information on the material breakdown and landfill diversion.
But there are a few problems with this theory.
Firstly, waste companies that hire out containers for ‘mixed general waste’ cannot know what their clients have put in those containers because they weren’t there when they loaded them, and when they unload them they are immediately mixed with other clients’ mixed waste rather than each skip being inspected and analysed independently.
Typically, therefore, when a waste company reports on the material breakdown of a client’s mixed waste collections, they quote their waste transfer station’s overall mix of waste rather than their client’s. Indeed, it’s not uncommon for them to provide a nice pie chart showing the mix along with a list of tonnages collected. This information is dutifully digested by the client and entered into their own records.
Secondly, for the same reasons as above, the landfill diversion % provided for the client’s mixed waste can only ever reflect the overall landfill diversion % of the waste company’s facility (typically for the last quarter or year) rather than the client’s own waste – because waste companies cannot monitor the processing of each load individually.
In other words, if a client fills ten ‘mixed general waste’ 12 yard skips with broken office furniture and the total weight of those loads was 10 tonnes, it wouldn’t be surprising for them to receive a ‘waste audit trail’ report (maybe even including a nice pie chart!) saying that those 10 tonnes were split was 60% inert, 10% wood, 10% metal, 5% paper, 5% plastic, and 10% other (namely applying the overall material mix of the transfer station) and that 75% avoided landfill (based on the fact that last year 75% by weight of all waste that passed through that facility was sent for recycling or reuse).
How is this information helping anyone and why are so many organisations turning a blind eye to its obvious failings?
The point is that is impracticable to expect a waste transfer station to give that level of information without increasing significantly its costs of operation. It seems to me that there is a real disconnect between what the waste industry’s clients want and what it is currently capable of providing but I’ve yet to hear these shortcomings discussed properly.
Surely, if clients want genuine waste audit trail reporting then rather than providing them with pie charts containing the wrong data, the waste industry should face up to the challenge and work with its clients to provide genuine long-term solutions.