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The Scottish Council for Development and Industry (SCDI) is an independent
membership network, which strengthens Scotland‟s competitiveness by influencing
Government policies to encourage sustainable economic prosperity. It is a broad-
based economic development organisation, with membership drawn from Scottish
business, trades unions, public agencies, educational institutions, non-governmental
organisations, local authorities, and the voluntary sector.


SCDI has a strong interest in environmental issues generally, with renewable energy,
energy efficiency, water environment, aquaculture and biodiversity having featured
prominently in its recent policy work. In addition, many of the components of
sustainable development in wider terms are part of sound business practice. A well-
managed company uses resources – both people and material – efficiently and certain
industries, such as tourism, increasingly depend on Scotland as a whole being seen as
a “clean, green” country. It is our view, therefore, that there is a great deal of
congruence between sustainable management of waste and sound business practice.
This is evidenced by a series of events organised by SCDI in conjunction with the
Envirowise, detailing waste minimisation advice services to business.

In summary:

      It is important to note that whilst the aim is to support progressive policies on
       waste, many companies already do so in a competitive market place.

      In an environment where regulatory and fiscal pressures are reducing the
       opportunities and increasing costs for hazardous waste disposal to landfill,
       there needs to be support and investment to provide better access to the full
       range of waste management facilities in Scotland. This should include an
       adequate network of accessible and affordable recycling facilities.

      We suggest that a review of existing data held locally within SEPA might
       fulfil the aim of better data collection on the amounts of commercial and
       industrial waste arisings. We encourage both SEPA and the Scottish Executive
       to keep to an absolute minimum any additional requirements for information.

      We suggest that the opportunities for sharing collection and storage facilities
       could be incorporated into the future planning and building of facilities.

Background to the consultation

The National Waste Plan (2003) sets out the Scottish Executive‟s long-term strategy
for the sustainable management of waste in Scotland - waste reduction, recycling,
composting and recovery - and commits the country to a series of targets set at
national level. To inform the Plan, 11 Area Waste Plans (AWPs) set out to identify
the best practicable environmental option (BPEO) for dealing with waste in the
respective areas. Together, the AWPs and the National Waste Strategy provide for
the strategic agreements on the sustainable management of municipal waste and form
the basis for applications to the Scottish Executive‟s Strategic Waste Fund.

However, the National Waste Plan has concentrated on household waste. 75 per cent
of Scotland‟s waste does not come from households. This consultation paper
therefore focuses on commercial and industrial waste, which for the purposes of the
paper, refers to non-household waste generated by the private, public and voluntary
sectors (excluding radioactive waste) and includes waste generated by commercial
activity (e.g. manufacturing) or from the activities of employees (e.g. waste arising
from consuming food and drink). The Scottish Executive‟s policy in relation to
commercial waste is similar to that of domestic waste, in that the overall aim is to
move further away from landfill, towards more progressive waste practices such as
prevention, recycling, composting, and the use of other technologies to treat residual

In the paper the Scottish Executive and the Scottish Environment Protection Agency
(SEPA) outline the steps already taken and seek views on what more could be done.
The intention is to develop a framework for non-municipal waste in Scotland. The
paper covers issues from recording and analysing data; the existing policy framework;
issues for SMEs and large companies; infrastructure; the use of the planning system to
promote waste prevention and recycling; the use of Pollution Prevention and Control
(PPC) regime; landfill bans, and the impending EC Thematic Strategy on Waste
Prevention and Recycling. However, from the outset the Scottish Executive notes the
following points:

      “The Scottish Executive does not intend to dedicate long-term significant
       financial resources to this area, in the way that we have for domestic waste.
       When it comes to waste produced by business, the “polluter pays” principle
       applies and we expect waste producers to foot the bill
      Given that waste producers will have to foot the bill, there is a clear incentive
       on producers to prevent waste arisings in the first place
      Where new waste treatment facilities are required, the Scottish Executive must
       ensure that the land-use planning system delivers fair decisions on where these
       should be sited
      The Scottish Executive will provide better information for businesses on the
       recycling options open to them.”

SCDI response:

1.      SCDI welcomes the opportunity to comment on the consultation paper. SCDI
supports both the Scottish Executive and SEPA focusing attention on this important
agenda and is encouraged by the intention to develop a framework, outlining a
strategy to encourage integrative and progressive policies for the reduction and
handling of non-municipal waste.

2.     In recent years the importance of environmental issues, not least on how we
deal with waste, has risen - quite rightly - up the social and political agenda: driven by
a combination of European legislation, environmental pressures and public
expectation. This has also placed significant pressure on Scottish businesses as they
seek to comply with more environmental regulation, taxation and legislation - all in
the face of intensified global competition from low cost producers in emerging
economies. Recent figures suggest that UK industry produces around 100 million
tonnes of commercial and industrial waste each year, costing industry about 4.5% of
turnover - roughly equating to £15 billion annually. It is important to note that whilst
the aim is to support progressive policies on waste, many companies already do so in
a competitive market place.

3.      SCDI commends to the Scottish Executive, research commissioned by
Envirowise (www.envirowise.gov.uk) from the Centre of Business, Organisations and
Society at Bath University. In their paper, „Environmental Management: Efficiency,
Compliance and Capability - Tomorrow‟s World Research‟, three key messages
emerge that encapsulate the need for the encouragement of business resource
efficiency: pressure on margins - particularly for manufacturers in light of global
price competition; large public and private sector organisations driving green
certification throughout their supply chain placing pressure on smaller companies, and
the legislative burden and future legislative agenda of sector and industry specific
legislation (e.g. REACH, ROC, IPPC, EU ETS, WEEE). Clearly, in the face of
increasing utility and raw material costs, waste disposal is set to become a significant
additional cost to the private, public and voluntary sectors alike. Therefore, the
opportunity to undertake waste prevention exercises will become the next frontier in
offsetting rising costs - improving efficiency and increasing competitiveness.

4.      SCDI notes that the waste industry is subject to significant legislation which is
in essence designed to increase the costs of disposal and encourage behaviour to more
environmentally sound practices such a recycling. Landfill tax is set to rise by 3% per
annum over the next five years and the requirement for higher environmental
standards through the EU Landfill Directive and hazardous waste management
changes will mean far fewer landfill sites being authorised to accept hazardous waste,
whilst a widening of the classification net will mean an inevitable rise in this waste
(during implementation of the Landfill (Scotland) Regulations SEPA estimate the
number of operational landfills will fall from 250 in 2002 to 110 at the end of 2007.)
The situation will be compounded with rising waste transportation and treatment costs
(estimated by SEPA to be in the region of 400 to 800 per cent in the medium term)
which will inevitably be passed on to customers. There is, therefore, a pressing need
for more integrated recycling infrastructure across Scotland, to provide accessible and
affordable alternatives to waste disposal. We welcome the Scottish Executive‟s
recognition that this should be a key aim of the proposed framework.

5.      But it is not just in the downstream recycling markets that attention and
resources need to be directed; SCDI also supports the information and initiatives
undertaken by the Scottish Executive, SEPA, local authorities and enterprise networks
- including advisory bodies such as Envirowise, Business Environment Partnerships,
WRAP and others: providing advice and information promoting the cost benefits of
waste minimisation and resource efficiency. Although these programmes have had
great success in terms of the cost savings achieved, we are of the opinion that there is
still some way to go in getting the message across to many businesses. We hope that
the formulation of this framework for non-municipal waste will go some way to
integrating and supporting sustainable waste management policies and practices
across Scotland.

Specific consultation questions:

Question 1: SEPA and the Scottish Executive are carrying out a review of the
National Best Practice Projects (NBPPs). We would welcome views on whether
the approach taken (considering specific waste streams and making
recommendations on best practice) remains appropriate. Consultees are invited
to comment on:
    (a) the overall approach taken in relation to NBPPs, and whether this
        remains appropriate.
    (b) waste streams/industrial sectors that might benefit from the NBPP
    (c) the aims and outputs that should be laid down and achieved when an
        NBPP project is established

6.       SCDI supports the principle of analysing current practices and facilities,
developing sector specific best practice guidance for the sustainable management of
waste. We believe that most sectors would benefit from a NBPP approach – perhaps
prioritised on hazardous waste streams and large volumes waste sectors. The clear
benefit these projects can provide will be significantly increased if the resulting
guidance is easily understood and readily available.

7.      As highlighted by Envirowise, EU legalisation will have an obvious effect on
the waste streams involved, now and in the future. The impending EU Thematic
Strategy on waste prevention and recycling should therefore be seen as an opportunity
to assess the current legislation impacting on the definitions of the disposal and
recovery of waste, encouraging wherever possible a balanced and flexible approach in
the transposition of European law.

Question 2:
(a) Do consultees consider there is more that SEPA and the Scottish Executive
could do to collect better data in relation to the amount of commercial and
industrial waste arisings?
(b) If yes, what? (options could include further surveys; collecting more detailed
information on waste types and introducing duties on waste producers to report
on the waste types and quantities produced.)

8.      As noted in the consultation, most waste from industrial sources is categorised
as non-municipal (i.e. it is not collected or controlled by local authorities) resulting in
difficulties for effective data collection. However, as noted by our members in the
chemical, whisky and farming industries, information on waste is already required
and produced and there is an increasingly large amount of paperwork and time
associated with regulatory compliance. The balance therefore will be to determine
why the data is needed, what the overall aim is, what type information is needed that
is not already provided and how best to achieve this whilst not increasing the
bureaucratic burden on businesses. We suggest that a review of existing data held
locally within SEPA might fulfil this aim. We encourage both SEPA and the Scottish
Executive to keep to an absolute minimum any additional requirements for

Question 3:
(a) Are the potential barriers for SMEs achieving more sustainable waste
management, outlined in paragraph 2.04, accurate?
(b) Are there any additional barriers?
(c) What action can be taken to tackle these barriers?

9.     The barriers to SMEs outlined in paragraph 2.04 are indeed accurate. The
main issues are cost, time, awareness, resource and facilities. SCDI fully supports the
Federation of Small Business‟s work in this area and the results of its recent
members‟ survey (www.fsb.org.uk) demonstrate that there is a clear need to help
small businesses with waste management.

10.     With SEPA estimating waste processing costs likely to rise by 400 to 800 per
cent in the medium term, due to the pressure on landfill, businesses - particularly
small businesses - need to have affordable alternatives to conventional disposal.
SCDI members have highlighted the lack of local recycling facilities for small
businesses - particularly, but not exclusively, in rural areas. Added to this, it is not
sustainable, regardless of company size, to export hazardous waste to England for
landfilling. In an environment where regulatory and fiscal pressures are reducing the
opportunities and increasing costs for hazardous waste disposal to landfill, there needs
to be support and investment to provide better access to the full range of waste
management facilities in Scotland. This should include an adequate network of
accessible and affordable recycling facilities.

11.    Another key area of assistance for small businesses is effective environmental
management, enabling waste minimisation which can result in significant cost
savings. With increasing disposal costs on the horizon, SCDI is concerned that many
businesses are still not aware of the fiscal and regulatory changes underway, or the
free advisory services on offer to them. This lack of awareness of environmental

issues was recently highlighted in the 2005 SME-nvironment survey by Netregs
(www.netregs.gov.uk). Although the survey identified that 42% of Scottish
businesses surveyed had acted to reduce their environmental impact, only 14% were
able to name an instrument of environmental legislation.

12.     Clearly, more needs to be done to develop the environmental awareness of
small businesses, such as signposting to sources of help and advice. Therefore, SCDI
welcomes the Scottish Waste Awareness Group‟s intention to develop a web-based
tool detailing recycling facilities for Scottish businesses and fully endorses advisory
services provided by organisations such as Envirowise, WRAP, Business
Environment Partnerships and others. We urge the Scottish Executive to continue to
provide funding to help increase the awareness and impact of these services.

Question 4:
(a) Can Local Authorities do more to provide advice to businesses on available
local services for recycling and waste prevention?
(b) Are businesses aware of any particular examples that could be used as a
model of good practice? If yes, please specify.

13.     SCDI understands that many local authorities already provide advice and
services to commerce and industry. Under the Environmental Protection Act (1990),
local authorities are obligated to collect commercial waste when asked to so and many
authorities also collect industrial waste, although they are not obligated to do so. If
the aim is to provide more structured advice and integrated services, the funding must
follow. SCDI encourages the Scottish Executive to widen the scope of the Strategic
Waste Fund where necessary, recognising the key role local authorities can and will
play in helping businesses meet their waste challenges, particularly in rural areas.

Question 5:
(a) Could Trade Associations do more to encourage businesses to address waste
(b) If yes, what? This may involve a signposting role rather than developing their
own guidance.

14.     Trade associations can and do encourage businesses to address waste
management, particularly by highlighting the cost savings that can be achieved in
doing so. SCDI is aware that trade associations have been an effective way for
government funded advisory services to engage with sectors and industries. As
always, the amount of work that can be undertaken is down to general awareness and
the levels of commitment that both sides are prepared to invest.

Question 6:
(a) Is it practical for businesses to share collection and storage facilities to
encourage recycling?
(b) Please detail any issues in relation to businesses using recycling centres (civic
amenity sites.)

15.      It will often not be practical for businesses to share collection or storage
facilities to encourage recycling given the limited physical options to do so, value of
materials, waste management consents and lack of opportunity to share arrangements
between larger companies that usually have their own agreements with particular
disposal service providers. However, the sharing of collection and storage facilities
could be more effectively developed with the right consideration and incentives. For
example, SCDI is aware that Highland Council is examining the possibility of using
recycling centres to permit the deposit of recyclate by business in the area. Although
there are difficulties in doings so - such as the need to calculate the full cost recovery
of recyclate from business - it is clear that with the right approach these initiatives can
be encouraged. We also suggest that the opportunities for sharing collection and
storage facilities could be incorporated into the future planning and building of

Question 7:
(a) Should the Scottish Executive, SEPA or other agencies do more to raise
awareness of waste issues amongst larger companies?
(b) Are any of the following points relevant to your industry?

i) Whether key decisions makers in companies are aware of the costs of waste.
ii) Whether further training would be helpful.
iii) Ensuring that decision makers consider all parts of the manufacturing
process and not just some of the processes
iv) Over-ordering of materials
v) Ability of companies to spend time on waste issues, given the other pressures
on business.
vi) Other (please specify)

16.     SCDI fully supports raising waste awareness issues with large companies.
Resource efficiency and waste minimisation potential can generate significant cost
savings, increasing competitiveness and improving productivity. This is particularly
important for larger companies operating in a highly competitive global economy
against low cost producers in emerging economies. Added to this, there are
opportunities to be gained with large companies driving resource efficiency and waste
minimisation through their supply chains. However, given that the vast majority of
Scottish businesses are SMEs, we are of the view that there should be a concerted
effort to maximise the dissemination of information and proliferation of services in
this area, particularly as the changing procurement practices of large public and
private organisations can have significant cost implications for smaller companies
attempting to comply with green certification requirements in their supply bids.

Question 8:
(a) Is there any more the Scottish Executive and SEPA or other agencies could be
doing in relation to the provision of infrastructure to deal with commercial and
industrial waste?
(b) If yes, what?
(c) Is there any more that the Scottish Executive and SEPA or other Government
agencies could be doing to take account of potential synergies between domestic
waste and commercial and industrial waste?
(d) If yes, what?

17.     Diverting more commercial and industrial waste away from landfill will
require increased infrastructure provision for recycling, composting treatment and
recovery. SCDI notes that this is a growth market with significant business
opportunities and job creation – central to the Executive‟s Green Jobs strategy.
Therefore, we encourage the Scottish Executive and its agencies to work together and
provide funding to promote the development of the market for materials recycling. At
a wider level we hope to see the recent changes in the Scottish Executive‟s Planning
Bill providing for the effective, expedient and equitable strategic development of
future reprocessing and treatment facilities. Finally, SCDI members have highlighted
the need to promote and publicise waste exchange projects - such as the Scottish
Industrial Symbiosis Programme (SISP) - where various producers can meet to
resolve waste issues.

Question 9:
(a) Do consultees consider that more should be done to promote site waste
management plans?
(b) If yes, what?
(c) Could planning conditions be used by local authorities to require developers
to produce construction and demolition waste prevention and management plans
for developments above a specified (financial) threshold?
(d) If yes, what should this threshold be?

18.    SCDI supports the Scottish Executive‟s view that there needs to be greater
scope to promote waste prevention and recycling in the construction and lifetime
phases of new development. This could be a positive opportunity provided adequate
resources and information are provided to allow both local authorities and developers
to engage and foster more integrated approaches to sustainable waste management.

Question 10:
(a) Do consultees consider targets could be introduced, after further
(b) If so, what areas could be covered and what targets could be set?
(c) Would the public sector be a possible candidate for targets?

19.    The danger of setting targets is that they become unrealistic and
disproportionate, particularly when waste data issues are outstanding. We would
suggest that perhaps voluntary targets in certain proactive and progressive industries
might be the best way of improving performance and meeting specific challenges.

Question 11:
(a) Are voluntary agreements a way of reducing the waste arisings; or reducing
waste going to landfill or encouraging recycling?
(b) If so, to which sectors could these be extended and what would be the main
areas which such an agreement should cover?
(c) Please give details of any industry that would consider entering into
voluntary agreements with the Executive on sustainable waste management.

20.     Although fiscal and regulatory pressures will be the most likely drivers in
reducing waste arisings, landfill reduction and recycling, SCDI believes that voluntary
agreements can and do increase recycling and general resource efficiency -
particularly where the cost-benefits of doing so are outlined. In terms of the sectors
and industries covered, we suggest that representative and advisory organisations
active in these areas would be the most obvious starting point.

Question 12:
(a) Do consultees consider that the promotion of waste minimisation within the
PPC regime should be strengthened?
(b) If yes, how?

21.     SCDI supports the principal of using the Pollution Prevention and Control
regime to identify best practice through the effective utilisation of resources
(including water and energy), techniques for material recycling, minimisation and
disposal of waste. Assessing and improving waste management and identifying best
practice on permitted sites should be supported by advisory services, so that meeting
the permitting process can be supported and the cost benefits of doing so identified.
This would greatly reduce the burden that can fall upon companies within the regime
and improve the integration process.

Question 13: Do consultees believe that it is feasible to introduce bans on the
landfill disposal of certain materials? If so, would consultees please identify the
materials for which a ban could be imposed.

22.     Enforcement and identification of small amounts of materials, and the
question of linked materials and their potential for recycling or reuse, would present
significant practical problems in introducing bans on landfill disposal of certain
materials. There would also have to be sustainable markets made available, which
would be easily accessible for the recycling and reuse of such materials.

Niall Davidson
Policy Analyst
Scottish Council for Development and Industry
December 2005


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