Waste Diversion Ontario (WDO) is considering a new battery recycling program that, if approved, would lower recycling standards in the province and permit “downcycling” of used batteries into slag rather than the current “upcycling” into added-value products.
At least that’s what a coalition of environmental organizations said in a letter to the WDO board dated January 20, which I reproduce in full below. The main points of the letter are also picked up in a Toronto Star editorial that focuses on the potential of the proposed plan to kill jobs at existing successful battery recyclers like RMC in Niagara Region. (I also reproduce the newspaper article below, as well as WDO’s letter to the editor about that article.)
These documents speak for themselves very articulately and are worth reading. I will simply offer a few macro perspective points:
The proposal comes from Call2Recycle (http://www.call2recycle.ca), an organization sponsored by the major battery companies that operates a voluntary battery recycling program in which consumers can drop off their spent batteries for recycling, free of charge. In Ontario the program offers 1,300 drop off locations where batteries weighing less than 5 kg each and also old cellphones can be deposited for recycling.
Call2Recycle deserves kudos for being a non-legislated voluntary program led by industry, and has diverted a lot of batteries from landfill disposal.
A cynic might say the battery industry set up Call2Recycle to stay ahead of, and possibly delay or thwart, product stewardship legislation with mandatory recovery rates and high recycling (“upcycling”) standards. Critics have noted almost since the program began that Call2Recycle doesn’t publish data that would allow policymakers to measure and track what percentage of batteries sold into the market are recovered and recycled.
The coalition letter states that Call2Recycle sends its batteries to an American smelter where much of the material ends up as slag or baghouse dust. This is a lower-value end product than what RMC, for instance, produces and Ontario stewardship rules specifically require WDO to favor programs that offer higher-end recycling over ones that allow “downcycling.”
Simply put, the battery policy debate in Ontario is about whether diversion-from-landfill programs with minimal recycling will be permitted in favor of (or even when they displace) recycling programs that meet a higher standard. We must ask, what’s the point of all this? Is it just about diverting material from landfill? Or is it about boosting total environmental performance? About creating new industries that utilize waste outputs as the raw material for higher-end purposes?
Perhaps Call2Recycle’s collection system could be utilized as part of a new stewardship plan to collect the materials and send them to places like RMC and the other processors who “upcycle” the materials. But the coalition is right in arguing against batteries being smelted into slag and road aggregate. These materials need to be dealt with locally and responsibly, for the highest-end purposes.
Here’s the newspaper article, first, followed by the WDO’s reply to that article.
Bad recycling decision must not be allowed to kill Ontario jobs: Editorial
Waste Diversion Ontario is considering a new battery recycling program that could hurt a thriving Ontario company.
In a province hungry for jobs, it’s disturbing to discover that the government-mandated organization charged with monitoring Ontario recycling programs is considering a plan that could kill a thriving — and local — battery recycling company.
Waste Diversion Ontario’s decision could ultimately wipe out 47 jobs at the Niagara Region’s Raw Materials Co. — the only Ontario business that meets lofty provincial recycling standards for the single-use batteries used in such things as toys and TV remote controls. Talk about market intervention.
Environment Minister Jim Bradley must scrutinize Waste Diversion Ontario’s decision to ensure that it follows government rules that require new recycling programs to have a “fair” impact on the marketplace and meet or exceed current recycling objectives. Precious jobs and environmental principles are at stake.
Despite the fact that Raw Materials Co. inspired Ontario’s recycling standards by turning some 80 to 92 per cent of single-use batteries into re-usable materials such as steel and fertilizer, its future is inexplicably at risk.
That’s because a company representing battery producers like Duracell and Energizer is making its third attempt to take over Ontario’s collection programs. Called Call2Reycle, it’s asking Waste Diversion Ontario to approve a plan allowing it to manage battery collections (despite previous criticism for low collection rates) and run the process that chooses the recycling processor.
So, who cares about a bunch of old batteries? Many groups, including those focused on green technology, fear this decision will lead to negative outcomes for business and recycling.
First, Raw Materials, a company located in the economically depressed town of Port Colborne, may well go under if Call2Recycle awards the job of processing old batteries to an American smelter it has used for many years. President James Ewles says flatly: “That would put us out of business.”
And second, Ontario’s lofty environmental standards for battery recycling may be compromised because of concerns that the smelter, located in Pennsylvania, turns a portion of the batteries into slag, often used as a filler for roads, which many environmentalists consider waste because it cannot be re-used.
That’s why the decision by Waste Diversion Ontario must be watched closely, especially by Ontario’s self-proclaimed “Jobs Premier,” Kathleen Wynne.
After all, Raw Materials is a home-grown success story, considered a “world class” recycler because up to 92 per cent of its batteries are turned into re-usable materials such as steel and fertilizer. The remaining paper and plastic is sent to a New York energy-from-waste facility.
It has recycled batteries for 20 years but since 2011 the company invested some $3 million into recycling technology and its 3,574 battery collection sites. They are located in stores, municipal government offices or run through charities, which get money in return.
At a time when too many Ontarians are forced into precarious work, the company has an annual payroll of $2 million for 47 workers, providing basic decent jobs that help people buy a home and raise kids. It’s strange then, that the government would allow a largely unaccountable organization like Waste Diversion Ontario to put these jobs at risk.
If Call2Recycle’s proposal is accepted, its spokesperson Joe Zenobio promises that its request for proposals for the recycling contract would be “fair, open and transparent.” But James Ewles of Raw Materials believes that Call2Recycle’s long-term relationship with the Pennsylvania-based processor, and the expectation of cheaper costs, will ensure it wins the bid.
Let’s be clear: in a competitive marketplace there’s nothing wrong with Call2Recycle’s attempt to expand its services.
What’s questionable — beyond job losses and doubts about environmental standards — is the fact that Waste Diversion Ontario is actively considering the proposal even though the Liberal government’s proposed Waste Reduction Act, Bill 91, with progressive new recycling standards, is still before the legislature at Queen’s Park. What’s the rush?
If the decision is approved, and a local success story faces closure, there will be a lot of explaining to do. Ontario’s government-mandated organizations should not have the power to destroy home-grown entrepreneurialism and the jobs it creates.
WDO REPLY TO TORONTO STAR EDITORIAL
January 20, 2014,
Letter to the Editor of the Toronto Star:
The Toronto Star editorial ‘Don’t kill a local success’ questions why Waste Diversion Ontario (WDO), the organization created by Ontario’s Waste Diversion Act to oversee Ontario’s waste diversion programs for designated materials , is considering a plan submitted to it by Call2Recycle to recycle single-use consumer batteries.
The simple answer is the law requires us to do so. It requires us to carefully review any plan submitted to us by an industry group wanting to take direct responsibility for recycling its products, rather than through an existing organization, called an Industry Funding Organization under current legislation.
WDO cannot simply determine when it will consider such a plan. Nor can it reject or approve such a plan, out of hand. The plan must go through a vigorous and transparent process of review that includes extensive consultations with affected and interested stakeholders, before a decision is then taken by the WDO Board.
In the case of the Call2Recycle plan to recycle batteries, that is exactly what we are doing. Their plan must document how the recycling program will be operated, its impact on the environment, the marketplace, and stakeholders, and how these impacts will be managed. It must include legally enforceable monitoring, review and other accountability measures to make sure they deliver on their commitment.
Call2Recycle’s plan was submitted to WDO last September. Since then, it has been reviewed by WDO – which is continuing – and undergone extensive public consultations – which are also continuing, including an opportunity to present views directly to the WDO Board. Only when WDO is satisfied that the review and evaluation process has been complete and transparent will it then make a decision on the plan.
As the Toronto Star correctly points out, important issues are at stake in any recycling plan: jobs, impacts on the environment, on the marketplace and on all stakeholders – be they consumers, collectors, processors, or municipalities. It’s our job to make sure these impacts are considered carefully and thoroughly. That’s exactly what we are doing.
Canadian Association of Physicians for the Environment | Canadian Environmental Law Association | Citizens’ Network on Waste Management | David Suzuki Foundation | Environmental Defence Canada | Greenpeace Canada | Local Enhancement and Appreciation of Forests (LEAF) | Registered Nurses Association of Ontario | Toronto Environmental Alliance
January 20, 2014
Waste Diversion Ontario Board
4711 Yonge Street, Suite 1102 Toronto ON M2N 6K8
Dear Board Members,
Re: Comments on Call2Recycle Battery Industry Stewardship Plan (ISP) proposal
We, the undersigned environmental and health organizations, have serious concerns with the Battery Industry Stewardship Plan (ISP) proposed to Waste Diversion Ontario (WDO) by Call2Recycle. We urge you to reject the proposed ISP on the grounds that it weakens recycling requirements for batteries in Ontario, is detrimental to the environment, and is contrary to Ontario’s commitment for greening the economy.
Battery Incentive Program
Ontario’s current Battery Incentive Program, operated by Stewardship Ontario, has the highest battery collection rate in Canada. While there is room and a public expectation for a tremendous amount of improvement in battery recycling in Ontario, over 1,000,000 kgs of single-use batteries were collected last year across the province of which 85% by weight was recovered through high-value ‘functional’ recycling by an Ontario-based processor.1
We are concerned with Call2Recycle’s proposal because it does not meet the fundamental criteria for approval of an ISP, which is that the environmental performance meet or exceed the performance of the existing program.
Definition of Recycling Efficiency Rate
Most significantly, the Call2Recycle ISP adopts a definition of recycling that is inconsistent with requirements under the Waste Diversion Act, and is environmentally harmful. The proposed definition will significantly weaken the recycling provisions applicable to batteries.
Call2Recycle states that the Recycling Efficiency Rate for the ISP will be calculated using the methodology from Directive 2006/66/EC of the European Parliament.2 This methodology allows for the inclusion of ‘slag’ byproducts from smelters in the calculation of recycled material. The consideration of slag will increase toxic pollutants contents in the recyclable material.
However, the existing Minister-approved Battery Incentive Program specifically excludes the weight of slag in the recycling efficiency calculations, and still achieves the targeted Recycling Efficiency Rate.3
By adopting a regressive definition of recycling efficiency, Call2Recycle’s plan will effectively be achieving a lower rate of recycling.
Definition of Recycling
Within the concept of recycling, there must be recognition that some forms of recycling are more beneficial, and thus must be promoted, over other forms of recycling. For example, ‘functional’ recycling or up-cycling is a term used to describe recycling a waste into raw materials that replace the use of virgin materials.
Stewardship Ontario defines two types of recycling with regard to Battery Recycling Effectiveness4:
a. “Up-cycling: The practice of recycling a material in such a way that it retains its original high-quality in a closed-loop industrial cycle.” This involves “…reusing those materials in high-value applications in order to displace the use of equivalent virgin materials in a like or other application (e.g., recovered Manganese used to produce new batteries or other manufactured products etc.)”
b. “Down-cycling: The practice of recycling a material in such a way that much of its inherent value is lost and cannot be recovered following its next use (for example, use of battery derived smelter slag in construction and/or aggregate for concrete).”
The proposed Call2Recycle ISP methodology would include ‘down-cycling’ in the overall calculation of recycling efficiency, whereas the existing battery stewardship program does not.
It is crucial that stewardship programs mandated by and regulated by the Province require the highest and best standards for recycling processes and efficiency.
Call2Recycle’s primary battery processing for its existing voluntary programs and provincial (BC and Manitoba) stewardship programs currently uses smelting technology to extract the valuable components of some battery types while incinerating the rest of the material into slag or baghouse dust (non-functional recycling, or ‘down-cycling’).
This issue is especially relevant in Ontario, as local battery recycling capacity exists that achieves high levels of functional recycling (or up-cycling’) by recycling nearly all of the battery back into secondary feedstock sold to manufacturers that use it as a direct replacement virgin substitutes.
Reject the Call2Recycle ISP
We call on Waste Diversion Ontario to reject the Call2Recycle ISP proposal immediately because it fails to meet the environmental performance of the existing program and in the process weaken Ontario’s efforts to improve its waste reduction programs.
In addition, the undersigned believe that the WDO should cease any decisions to approve this ISP, and should undertake to commission an independent review of recycling efficiencies of the various recycling technologies being offered. Such a review will provide the desperately needed scientific evidence to identify the most effective and efficient forms of recycling.
Toronto Environmental Alliance (Emily Alfred, Waste Campaigner; 416-596-0660) Canadian Environmental Law Association (Fe de Leon, Researcher; 416-960-2284)
Canadian Association of Physicians for the Environment (Gideon Forman, Executive Director) Citizens’ Network on Waste Management (John Jackson, Coordinator)
David Suzuki Foundation (Faisal Moola, Director General, Ontario and Northern Canada) Environmental Defence Canada (Keith Brooks, Program Manager, Blue Green Canada) Greenpeace Canada (Joanna Kerr, Executive Director)
Local Enhancement and Appreciation of Forests (LEAF) (Janet McKay, Executive Director) Registered Nurses Association of Ontario (Doris Grinspun, Chief Executive Officer)
Minister Jim Bradley, Minister of the Environment
Gord Miller, Environmental Commissioner of Ontario
John Armiento, Manager, Waste Diversion Unit, Ministry of Environment
Jodi Tomchyshyn London, Manager of Policy & Planning, Waste Diversion Ontario