National Waste Policy Regulatory Impact Statement

Indicative benefits from better information and data collection under a national approach

The current proposal in the National Waste Policy is for all governments to commit to a national framework for data collection on waste management and resource recovery. Under this commitment, government would agree to develop a national waste data system though the framework for this data system is yet to be agreed.

This would address recommendations made by the Productivity Commission in its Waste report (See Box 4.1).

2. 
   
   

Productivity commission Waste report: Recommendation 12.3

The Australian Government should work with the state and territory Governments to: develop and implement a national definition of waste and a national waste classification system; review the appropriate balance between prescriptive and risk-based classifications of waste; standardise, coordinate and improve the efficiency of current processes for granting exemptions to recoverable resources from irrelevant environmental controls; and explore opportunities to achieve further consistency in regulatory standards applying to waste.

Source: Productivity Commission 2006

There is currently no national information system for:

• 
  efficiently determining whether we are meeting our international obligations such as the Basel Convention; or
  
• 
  assisting policy makers in determine the appropriate policies to meet community objectives for waste management (such as collection, treatment etc).
  

For this Regulation Impact Statement, the key question is, while there are a number of ways in which data collection could be improved, what is the case (based on potential net benefit) for applying a national approach to this problem?

There is sound research, and examples in related areas, which make the case for a national approach in this field. The Waste Management Association of Australia (WMAA), in its 2008 evaluation of waste data arrangements, has estimated that the costs to their member organisations (including some local governments) of participation in the current fragmented and duplicative arrangements are $9 million per year, with a more coordinated approach leading to an estimated 35 per cent saving (at an estimated cost of $5.7 million). As part of this research, 217 separate waste and recycling streams were identified, with 144 of these being recurring streams (i.e. annual reporting versus one-off collections). Of these requests:

• 
  52 per cent are by voluntary survey;
  
• 
  21 per cent are by voluntary audit;
  
• 
  21 per cent are by compulsory survey;
  
• 
  4 per cent are publicly available requests; and
  
• 
  2 per cent are by compulsory audit.
  

As shown in , the cost burden of providing data into the current system falls on a range of parties, including local governments, resource recovery and waste disposal businesses. The potential benefits of a more streamlined approach to data collection would benefit each of these stakeholders, primarily by reducing the ad hoc nature of data collection and providing greater consistency of definitions and categories of data. There is also a quality dimension to this data collection issue. Heavy reliance on voluntary survey information may help reduce cost imposts, but questions remain over the utility and reliability and comprehensiveness of the information collected for policy and decision purposes.

Figure 4.1

Requests for data – source of data



Source: Waste Management Association of Australian (WMAA)

In related fields, such as energy and greenhouse data reporting, COAG principles of regulatory reform have led to the formation of a national reporting framework (the National Greenhouse and Energy Reporting System). The key areas of benefit from this system, as identified in the Regulation Impact Statement, are: a single, cooperative, streamlined reporting system; removal of current duplicative reporting arrangements; consistent robust and comparable information to inform decision making; and information that is publicly available.

Indicative benefits from improved management of tracking of hazardous waste

Data and information for many areas associated with the hazardous aspects of waste are widely recognised as being poor and needing improvement to allow decision makers to better assess the risks presented by hazardous articles and materials, to select appropriate management initiatives, to plan for future treatment capacity, to ensure that we are protecting human health and the environment, and to ensure Australia is meeting its international obligations. Since 2001 Australia has reported the generation of over 6.4 million tonnes of hazardous waste (as defined under the Basel Convention) and exported about 210,000 tonnes for treatment overseas. However, the figure of 6.4 million is likely to be an underestimate, given the different reporting mechanisms by states and territories.

Data and classification are important precursors to identifying and managing hazards in an appropriate way. Significant and avoidable compliance costs can be associated with the misclassification of waste as ‘hazardous’. Conversely, major risks to health and safety can arise from misclassification of waste materials as non-hazardous.

Materials and products containing potentially hazardous substances are found in a range of areas, including:

• 
  commercial and industrial waste — such as that specifically identified as hazardous under Australia’s international obligations such as the Basel and Stockholm Conventions;
  
• 
  municipal solid waste — such as household chemicals and articles containing hazardous chemicals, and bio-waste including medical waste;
  
• 
  construction and demolition waste — such as treated timber, floorings, plastics, paints, polymers, coatings, solvents and adhesives which contain hazardous materials; and
  
• 
  biosolids — particularly sewage sludge which may be contaminated by a range of household chemicals and pharmaceuticals.
  

An audit of waste received at the Global Renewables Eastern Creek Alternative Waste Treatment Facility highlights the risk represented by waste contaminants. It revealed that hazardous materials made up an average of 3.17 per cent of the household rubbish received over five days. Materials included batteries, insecticide containers, motor oil, medicines, syringes, tubing used for dialysis, computer equipment and gas cylinders. However, there is little sound analysis of the high end risks from contamination by hazardous waste. It can also be important that different tracking and treatment regimes should be applied appropriately to different classes of hazardous waste materials.

The Regulatory Impact Statement for the proposed Environment Protection (Industrial Waste Resource) Regulation 2009 by the Victorian Environment Protection Agency sought to ascribe a value to the appropriate handling of industrial wastes. The Statement highlights the lack of good quality analysis of spillovers cost and benefits in this areas, but notes general community acceptance of the fees associated with Category A ($1000 per tonne) and Category B ($500 per tonne) prescribed wastes. In the absence of better information on actual health or environmental risks, this might be used as a rough guide to the minimum benefit per tonne that society derives from proper disposal or re-use of these hazardous materials.

In the development of this regulatory impact statement EPA has undertaken a significant consultation and stakeholder engagement process which gave the opportunity for industry or the community to raise concerns about the schedules or treatment requirements. The consultation process has indicated that the mandatory treatment of Category A waste is not an issue of concern. This would suggest that society’s value of treatment of prescribed industrial waste is greater than the $1000 per tonne cost.

A similar argument could be made for Category B prescribed industrial waste, which is estimated to cost $500 per tonne to treat. The consultation process has indicated that this is not an issue of concern. (EPA 2009 Environment Protection (Industrial Waste Resource) Regulations - Regulatory Impact Statement, p.51)

While this ‘proxy’ value is not ideal for considering the costs associated with hazardous waste management, the relatively high price per tonne nevertheless gives some indication of the risk that the community sees as inherent in hazardous waste. Putting an exact dollar value on hazardous waste remains problematic.

The scale of the requirement for hazardous waste management in the future is equally difficult to quantify, particularly when considering new international requirements such as the Legally Binding Instrument on Mercury (currently being developed) and the additional nine Persistent Organic Pollutants, some of which are contained in consumer goods. Risks and community costs relating to health and other social factors arise from piecemeal policy making and regulation in this area.