Wednesday, 19 December 2018

District Council and plastic pollution >>> Sending plastic to the correct reprocessor: a follow-up FOI request

The District Council is quite pleased with its performance when it comes to dealing with waste:
Futures Forum: Simplifying councils' household recycling collections in the government's resources and waste strategy

Back in the summer, a Freedom of Information request was made to the District Council, specifically about their plastic waste:
Futures Forum: District Council and plastic pollution >>> What percentage is recycled, what percentage is incinerated and what percentage goes to landfill? Some answers received...

A further request has just been lodged:

Sending plastic to the correct reprocessor - to EDDC - December 2018

Dear East Devon District Council,

On 28th June I made a Freedom of Information request: https://www.whatdotheyknow.com/request/sending_plastic_to_the_correct_r_2#outgoing-782080

Thank you for your reply of 9th July: https://www.whatdotheyknow.com/request/sending_plastic_to_the_correct_r_2#incoming-1185704

In your reply, you stated: “if you feel dissatisfied with the way we have responded to your request, please contact our Monitoring Officer, Mr Henry Gordon Lennox, to request an internal review.”

Rather than taking that step, I would rather compose a new request for information and provide further clarification.

INTRODUCTION:

I would like to make my formal request under the Freedom of Information Act 2000. I am also making this request under the Environmental Impact Regulations 2004 which require disclosure on the part of Local Authorities.

The basis for my request is information made available to the public:

1) the text on the DCC website http://www.recycledevon.org/what-happens... states:
“Plastic: What happens: plastic is sorted into different grades and then sent to the correct reprocessor where it is turned into new plastic items such as bottles, fleeces and food containers.”

2) the text on the EDDC http://eastdevon.gov.uk/recycling-and-rubbish/reduce-reuse-recycle/recycle/where-does-my-recycling-go/ states:
“Household Plastics collected from the kerbside are taken by various companies to be recycled. The plastic is cleaned, shredded and used to remake other materials such as garden furniture, bins, insulation and fleece clothing. [Last updated 22 October 2018]”

In view of these texts and your earlier initial responses, I would be grateful if you could answer the following questions.

HOW PLASTIC WASTE IS HANDLED:

I had originally asked “What systems do you use to determine how the "plastic is sorted into different grades"?” and “How much of the plastic is sent on to "reprocessors" and how much is dealt with by other means, such as landfill waste, incineration or other methods of disposal, by yourself and by other bodies?”

You stated in your reply: “EDDC sell plastics collected as a mixed plastics grade. The mixed grade goes to a number of plastic recycling plants who then sort it into grades and they then sell it on to a number of processors. The missed plastic grade is sold to a number of plants who provide the best prices at the time. Our most recent loads have gone to Roydon Polythene in Manchester but this will change regularly.” And: “A small proportion of plastic sent to any processor will be rejected for quality and other reasons and alternative means of disposal is used for this fraction.”

If I might be more precise in my questions following your responses:

> Are all the plastics which EDDC collects of “mixed grade”?

> What happens to the plastics which are not collected and which are not sold?

> How do you determine which plastic recycling plants to send the mixed grade to? Is it simply a matter of “who provide the best prices at the time”, or are there other criteria?

> What are the “alternative means of disposal” used for the rejected plastic?

If I might also provide these related questions:

> What percentage of all plastics does not go into processing? [eg: black plastics]

> What percentage goes to incineration in Devon, in the UK and abroad? [eg: tonnage measurements available at incinerator]

> What percentage is sold on the open market?

> What residual is disposed of as landfill waste? And what steps are taken to ensure that none of this residual escapes to pollute the environment?

And if I might ask further questions with regard to your on-line text: “The plastic is cleaned, shredded and used to remake other materials such as garden furniture, bins, insulation and fleece clothing.”

> What percentage of the plastic is “used to remake other materials”?

> What is the lifespan of these new plastic items?

> Which of these new plastic items are themselves recyclable?

DETAILS OF PLANTS AND PROCESSORS:

> Could you provide me with more details about the plastic recycling plants you send the plastic to? And the processors to whom these plants sell the sorted and graded plastic?

> Could you give me their full postal addresses and website addresses?

> Have there been any changes to the original list of contactors since you first provided it?

CONTRACTUAL INFORMATION AND AUDITING PROCESSES:

I asked you several questions to which you replied that “EDDC do not hold this data” or “This question needs to be addressed to the processors”.

> I would nevertheless like to know: What systems do you use to keep track of the plastic to ensure that it is properly dealt with, from it leaving the sorting/ grading process to the final end-use?

I asked you specifically: “What systems do you use to keep track of the plastic to ensure that it is properly dealt with, from it leaving the sorting/ grading process to the final end-use?” I appreciate that much of this is covered by waste management legislation, the duty of care owed by the parties who are transporting it and the regulation by the Environment Agency.

However, I also appreciate that the local authorities have clearly taken on a responsibility, having made a public commitment: DCC has declared that “plastic is sorted into different grades and then sent to the correct reprocessor where it is turned into new plastic items”; and EDDC have similarly declared that “Household Plastics collected from the kerbside are taken by various companies to be recycled. The plastic is cleaned, shredded and used to remake other materials such as garden furniture, bins, insulation and fleece clothing.”

> In order to ascertain the systems which the Council use to ensure that the “correct reprocessor” is taken on and that the “various companies” are chosen with due process to recycle the plastic; that the plastic is “sorted into different grades”; and that it is “turned into new plastic items” and “used to remake other materials” - I would like to ask you to provide me with the full, unredacted tendering and contractual documentation made between you and the plastic recycling plants you send the plastic to.

> I would also like you to provide me with any documentation relating to auditing of these contractual agreements. By auditing, I mean the mechanisms by which the plants and processors can be made fully accountable and the systems by which compliance is reported back to the Council.

CONCLUSION:

Finally, I appreciate the challenges which councils generally are facing:
https://www.local.gov.uk/about/news/china-waste-ban-impacting-council-recycling-services-and-costs
https://www.theguardian.com/environment/2018/oct/20/plastic-recycling-industrys-problems-costing-councils-up-to-500000-a-year
https://www.telegraph.co.uk/news/2018/10/19/plastic-becoming-expensive-recycle-councils-say-giant-waste/

and I certainly do not wish to undermine the efforts of the Council:
https://www.telegraph.co.uk/news/2018/10/18/plastic-recycling-crisis-first-council-plans-tell-households/

or the confidence which people have in these efforts:
https://www.lgcplus.com/services/environment/lga-rejects-call-for-nationally-consistent-recycling-service/7026166.article?blocktitle=Latest-News&contentID=21622

However, in view of the clear determination of these efforts and considering the Council's public declarations, I would like to be given reassurances as to how plastic waste is managed.

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