In June 2005 the National Used Oil Material Advisory Council (NUOMAC) published the results of a Program Review of “UOMA style” used-oil material programs operating in British Columbia, Alberta, Saskatchewan and Manitoba.
The media release that accompanies the report touts the UOMA as a, “…leader in program design, collection and compensation scheme compared to 14 other global used oil management programs.”
The Program Review, prepared by BearingPoint Inc., consists of 24 survey questions posed to 119 respondents, of which 30 were interviewed in depth. In addition to the survey, the Program Review purports to benchmark the western UOMA programs against non-UOMA style programs in other jurisdictions.
Unfortunately, the choice to use a survey as a means to answer questions that require empiric and quantitative responses is analogous to assessing the aerodynamic design and structural integrity of an airplane by polling the passengers on it.
Consider this question: “Overall, have UOMA’s programs improved the collection of used oil materials in Western Canada?” To answer the question in a factually relevant manner, a respondent would need to know current recovery rates in the context of the pre-program baseline recovery rates for used oil, used-oil filters and used-oil containers.
In that regard, BCUOMA claims that it was responsible for a 12 per cent increase in used-oil recovery in its first year of operation (from a 60 per cent to 72 per cent or 44.1 million liters in 2003). In 2000 (as a civil servant) and 2002 (in a paper he authored in MITs’ Journal of Industrial Ecology) Ron Dreidger (currently Executive Director of BCUOMA) reported that, “More than 40 million liters (L) of used lube oil have been collected annually through the EPR system established under this (return-to-retail) regulation.” The recovery of over 40 million liters of used oil in 2000 translates into a recovery rate of more than 65 per cent, which puts 2000 pre-BCUOMA recovery rates to within 5 per cent of the 72 per cent used-oil recovery rate claimed by BCUOMA for 2003.
In other words, BCUOMA has not had any effect on the collection of used oil in British Columbia. This contention is supported by several of the largest used-oil collectors in that province.
In addition to the survey, the Program Review attempts to make a “technical” case regarding the merit of the UOMA’s collection scheme and lack of merit associated with re-refining. Specifically,
— UOMAs have the highest used oil recovery and re-refining rates and any effort to promote re-refining will undermine used oil collection rates. The Program Review contends that “UOMA is a world leader in maximizing used oil collection rates (over 75 per cent) and re-refining rates (30 per cent).”
Yet, according to Waste Diversion Ontario, Ontario (a non-UOMA jurisdiction) has both a higher used-oil recovery rate (~80 per cent) and a higher re-refining rate (45 per cent). On a global basis, and contrary to the un-sourced data provided in the Program Review, the used oil recovery rates claimed by UOMA, are at best average. (See chart under Posted Documents atwww.solidwastemag.com). Insofar as re-refining is concerned, the launch of the BCUOMA program in July 2003 caused Newalta’s re-refinery to lose at least nine million litres of used oil to collectors shipping used oil for burning as a waste-derived fuel. British Columbia is collecting no more oil than it did pre-BCUOMA and is re-refining significantly less;
— Burning used oil is environmentally equivalent to re-refining and used-oil programs should not “favor” one management option over another. The Program Review states that, “In general, studies by the OECD and EUROPIA (the European oil industry lobby group analogous to CPPI) indicate that the environmental and energy benefits between combustion and re-refining are well balanced.”
However, insofar as the cited OECD report Improving Markets for Secondary Materials: Case Study on Oils is concerned, the OECD stated in July 2005 that, “…this report is presently classified, i.e., for official use only” and, “Following this first draft, the report has been revised and is still under review by OECD Member-countries,” and (finally) “…the present version should not be used nor quoted by unauthorized persons or institutions.” The second reference, the EUROPIA “study,” is a review of dated life-cycle studies of outdated European re-refining technologies. Nevertheless, NUOMAC cites this source as another case against re-refining in what amounts to a smear of the environmental, commercial and economic efficacy of state-of-the-art North American re-refining operations.
The UOMA Program Review offers oil producers on UOMA boards, recycling councils and public relations officials at environment ministries a lot about which to “feel good.” Anybody interested in the facts, however, may not be so thrilled.
Usman Valiante is principal of Corporate Policy Group LLP in Mono Township, Ontario and also a contributing editor to this magazine. His clients include oil re-refiners. Email Usman at firstname.lastname@example.org