Separate ways: a commercial waste case study

It’s now a little over two years since the separate collection requirements under the amended Waste (England and Wales) Regulations 2011 took effect. For waste collectors, this made it compulsory to ensure that, if they were collecting paper, metals, plastics or glass, they did so by way of separate collection – subject to the rather hard to interpret condition that separation is ‘necessary’ and ‘practicable’ (‘TEEP’).

With this legislation now firmly entrenched, how hard would you imagine it might be to obtain separate collections of these four materials for business premises at the heart of one of England’s major cities?

Has bins

At Eunomia’s Bristol head office, we have for years strictly source-separated our waste into:

• Paper
• Card
• Cartons
• Metals
• Glass
• Rigid plastic
• Plastic film
• Food

We also separate electronics, batteries and various other items for reuse and recycling. Many of these streams are quite small – we produce a box full of glass perhaps every three months (with quite a lot extra at Christmas!), and a sack of cartons around every two months. Some of our food waste is composted on site using a wormery, with perhaps 50 litres a week of tough or acidic material that the worms can’t cope with being sent for treatment.

That’s our established system, and it works – less than 5% of our waste goes into the residual stream. For a long time, we’d obtained all of our collection services from a small, local provider, who came around in a box van each week to pick up whatever material we set out. They ran a specialist recycling round for a relatively small number of businesses, and had sufficient space to bulk up materials like cartons and plastic film until they had a sufficiently large quantity to send for reprocessing. However, competition from low-priced co-mingled collections led them to decide to stop their waste round and focus on their office clearance business.

Like most satisfied customers, we hadn’t tested the local market for quite a while; however, with the separate collection requirements introduced by the Waste Regulations, we didn’t envisage that it would be too difficult to meet our requirements, principal amongst which was that we would maintain our recycling rate. It might take more than one contractor to cover the four key materials; and perhaps our choice might be limited if we wanted to ensure that the plastic film and the cartons (whether separated or mixed with other streams) would go to beneficial use; but surely it couldn’t be all that difficult, especially for an environmental consultancy. How wrong we were….

Going for broker

We started off as most businesses looking for a waste collector would: we got on the internet and found the details of some local collectors and brokers. After a couple of hours, we had around a dozen that seemed to offer some separate collections. Then we got on the phone, which was where the fun started:

• Quite a few turned out not to offer separate collections after all – they were happy to take a sack of source-separated material, but it would get mixed with other dry recycling on the collection vehicle.
• In other cases, we were passed from the call centre to the regional sales manager to the depot manager in an attempt to find out whether what we were asking for was operationally possible. The cartons and film were a particular problem; those willing to accept them wanted them mixed with other materials, and seemed to regard them more as a tolerable contaminant than a target material.

A worm welcome: even food waste is separated into two streams to allow some to be managed on site. Photo: Peter Jones.

• Many were unwilling to collect food waste from the 24L caddies that we use, and would only come to us if we agreed to switch to a bin. Several insisted on a 240L bin that would take us weeks to fill, and which would be difficult to accommodate in our Georgian building.
• Many tried to reassure us that, despite being unable to take some of our material for recycling, they would offer a “zero waste to landfill” service – perhaps not realising that we were aiming rather higher up the waste hierarchy

None, it turned out, was able to accommodate the degree of separation we, and the Waste Regulations, were looking for.

A little help from our friends

Then we tried something that would be harder for most businesses – we got in touch with some waste sector contacts, and asked if they, or anyone they knew, could provide the type of source separation we were looking for. Even armed with this well-informed advice, to our surprise there wasn’t a lot on offer:

• One national waste collector was willing to let us piggy-back on the source separated collections it was providing for Bristol University, but even that would involve mixing paper with card, and plastic with cans. No separate collections of plastic film or cartons were available, although there was scope to mix these with some of the other materials. Further, even this level of separation wasn’t going to be available for long, as the university was switching to a co-mingled system.
• We were referred to another smaller collector based around 40 miles away. This initially looked promising, but turned out that we were a bit remote for them – and in any case, they couldn’t accept our plastic film, even as part of a mixed plastics stream. We could have filled the gap by contracting with a specialist for a plastic film collection, but they wanted to charge a rather eye-watering £72 to pick up quite a small box of material.

It appeared that our efforts would be in vain, and for want of a collection service we would find ourselves unable to maintain our recycling rate. Thankfully, though, we were able to speak with Bristol Waste, the recently formed local authority company set up by Bristol City Council to run its waste and litter services. Because Bristol collects source-separated household recycling, the commercial waste service it is now introducing will be collecting commercial recycling in separate streams too, some of it co-collected on household vehicles where feasible, which helps them to keep the costs low.

Boxing clever: Eunomia’s array of containers allows seven streams of dry recycling to be separated. Photo: Peter Jones.

We’re going to have to mix some of our light card with our paper, and are still trying to resolve whether they can take separated plastics and cans to save them having to sort them at the depot. We’re also still seeking clarity on what exactly will happen to the cartons and the plastic film, and while they may well be accepted for recycling, it seems unlikely that we’ll be able to keep producing them as separate streams. However, the council’s service seems affordable, and is as close as we are likely to get to what we are looking for.

Law unto themselves

In the end, then, the timing has worked out for us. A few months earlier and we would not have been able to find a real source-separated collection system at all. Even now, it’s only the fact that Bristol Waste operates a source-separated household collection service that has led them to offer commercial collections on that basis, and we have to hope that they will be successful in selling it in a market so dominated by co-mingled recycling.

It is possible that Bristol is an exception, and that elsewhere in the country source separated commercial recycling thrives – but that seems unlikely. While would-be source separators in England may not be well-served, Wales seems set to do things differently. In the Environment (Wales) Act 2016, the Welsh Government took powers to require commercial recycling services to operate on a source-separated basis. At present, such collections seem to be no more commonplace than they are in England, so if Wales acts it will mean a significant shake-up in the market.

Our recent experience, however, suggests that the waste regulations have had very little effect on the commercial collections market in England. That is unsurprising: there has been no enforcement of the rules, whose drafting in any case doesn’t lend itself to strict interpretation. Wales appears to have decided that additional, clearer legislation is the best way to make progress; in the absence of anything similar, English businesses that want to source separate their recycling may continue to struggle to find someone willing and able to collect it.