A new critique of a used-oil stewardship “Program Review” raises serious doubts about the survey methodology, data and program performance claims of an organization that represents western Canada’s used-oil programs.
The critique is released on October 21, 2005 on the website of trade magazine Solid Waste & Recycling (Look under Posted Documents on the left side of the magazine website www.solidwastemag.com)
Usman Valiante, principal of Orangeville, Ontario-based Corporate Policy Group LLP, wrote the critique of the National Used Oil Management Advisory Council’s (NUOMAC) 2005 Program Review of Used Oil Management Association (UOMA) style used-oil material programs operating in British Columbia, Alberta, Saskatchewan and Manitoba.
“This is a serious and quite scholarly review of the programs, and how they assess themselves,” says Guy Crittenden, editor of Solid Waste & Recycling. “The findings are very disturbing and call into question the environmental performance of the western Canada-based used-oil programs and how they measure their own achievements.”
The critique addresses three claims made by the UOMA Program Review:
1. The western UOMA model is not a, “leader in program design, collection and compensation scheme” Valiante writes that a more complete review of non-UOMA jurisdictions not considered by the Program Review identifies many non-Canadian, non-UOMA jurisdictions that exceed UOMA jurisdictions in used-oil recovery performance. With regard to Canadian jurisdictions, there is strong evidence that pre-UOMA program British Columbia and Ontario have experienced used-oil and used-oil filter recovery rates under their EPR/Polluter pays regulatory regimes that are equivalent or higher than those of UOMA jurisdictions.
2. The contention that “the made-in-western Canada model is a world leader in maximizingre-refining rates (30%)” is false. On the contrary, there is strong evidence that the BCUOMA program in British Columbia caused the resident re-refiner to lose almost 30 per cent of its provincially derived used-oil volume and that UOMA-type programs undermine re-refining.
3. The contention that re-refining used oil and burning it as a waste-derived fuel are environmentally equivalent and that, “there is no ‘right answer’ for the appropriate end use for used oil,” is unsupported. Unbiased, scientific life-cycle inventories and assessments of modern re-refining technologies provide strong evidence that re-refining provides distinct and significant environmental benefits across a wide range of environmental parameters (i.e., air emissions, natural resource consumption etc.) over burning used oil as a waste-derived fuel.
The critique also comments on the applicability of surveys as a program review methodology.
A copy of the CPG critique can be downloaded from the Posted Documents section of the Solid Waste & Recycling magazine website (under the October/November edition subheading).
An article that summarizes the report findings, entitled “Smear Campaign” by contributing editor Usman Valiante, will appear in the October/November edition of Solid Waste & Recycling magazine.
Contact Usman Valiante at:
Corporate Policy Group LLP
633329 Highway 10 RR#4
Mono Township, Ontario, Canada