Manhattan Citizens' Solid Waste Advisory Board
Waste Prevention Committee
prepared by Marjorie Clarke, Vice Chair
May 21, 1991
LIST OF REDUCTION INITIATIVES FOR MODELLING IN DOS WASTE PLAN
(included as an appendix to the Waste Prevention Appendix in DOS' 1992 Solid Waste Management Plan)
The Waste Prevention Committee of the Manhattan Citizens' Solid Waste Advisory Board recommends that DOS and its consultants perform a number of "maximum source reduction" scenarios as part of the ongoing comprehensive 20-year Integrated Waste Planning process. Since the NYSDEC is obligated to judge the adequacy of the City's long-range plan, in part, on how faithfully it follows the priorities of the solid waste hierarchy, and thus, how exhaustively it plans to implement waste prevention initiatives, the City is obligated to be aggressive in its investigation and analysis of these initiatives. Imposition of arbitrary limits of 8+% for waste prevention's potential, as appears to be the case in the City's planning process in general, and in the consultants' report (Table 3) in particular, regardless of the number of reduction initiatives examined, is not in keeping with the State's and EPA's hierarchy, in which waste prevention is to receive HIGHEST PRIORITY. So from a legal point of view, it is essential that NYCDOS vigorously pursue as many avenues as possible to reduce the quantity and toxicity of waste generated. Of course, it has always been the position of the Waste Prevention Committee that to maximize waste prevention activities in the City, DOS be restructured such that waste prevention planning and implementation take place at the same level in the organization as recycling and waste disposal activities.
Moreover, since early information from the consultants indicates that the cost per ton of implementing a certain minimal level (8.25%) of four waste prevention initiatives is $20 vs. $250 to $300 for other, lower priority collection, processing, and disposal alternatives, it also makes absolute sense from an economic point of view that much greater time and resources be invested in exploring and implementing additional and alternative initiatives.
Finally, maximizing waste prevention also makes sense from an environmental point of view since minimizing unnecessary mining, manufacturing, and transportation of virgin materials and products made from them, as well as the avoidance of collection, processing and disposal, will certainly result in environmental benefits.
Specifically, the MCSWAB Waste Prevention Committee recommends that DOS and its consultants explore the reduction potential of the initiatives presented below. Some of these proposals are law; others are legislative proposals. Though this list of initiatives has been in development since December, 1990. Many of the proposals contained herein are similar in concept to proposals recently described to you by your consultants, Marian Chertow and Cal Recovery Systems; these are denoted by asterisk. That this list does not necessarily contain all the initiatives alluded to in the consultants' report does not indicate that the committee is opposed to them.
As some of these initiatives address narrowly-defined components of the waste stream, several, targeted at different segments of the waste stream, could be assumed to operate at the same time and would constitute a single alternative scenario. This concept has also been proposed by your consultants. In other cases, we suggest that some of the initiatives are to be explored as substitutes for other, similar initiatives in order to facilitate sensitivity analysis. In still other cases, the effects of some of the proposed initiatives will not likely affect the volume or weight of waste, but should have a substantial impact on waste toxicity. The impacts of these latter initiatives on waste toxicity and consequently on the environmental impacts associated with recycling, composting, incinerating and landfilling wastes with this altered composition should be seriously considered. Finally, since legislation and regulation are not only good mechanisms for instigating volume and toxics prevention, but also can promote recycling, the Committee has included here a category of recycling-related initiatives.
We will be looking forward to reading and critiquing the modeling of the potential tonnage savings and economic and environmental cost/benefit of these and other waste prevention initiatives you have received.
Volume - Related Initiatives
1. To discourage overpackaging, require manufacturers to include product/package ratio (by volume) on the label and a requirement that no product have more than 10% packaging by volume.
2*. To discourage waste generation in general, institute variable waste disposal charges for residential, commercial and institutional waste. Charge institutions, homeowners and individual tenants (model various linearly increasing fee structures) for special bags (containing no toxic precursors) for non-recyclables. Issue, free of charge, other, distinctive bags for collecting recyclables. Also require that these extra bags in the waste stream be removed from the waste stream and recycled by the supplier of these bags (or his agent) at his cost and benefit as part of his contract with the municipality.
3*. Institute variable waste disposal charges by means of tags and stickers, sold to landlords, homeowners, and institutions and a requirement of specific size reusable containers.
4. To educate consumers about the true costs of packaging (and probably direct them towards less substantial packaging) require that, for each consumer product, the percentage of total cost which is accounted for by packaging be displayed on the package.
5*. Prohibit the sale of food in disposable packaging and with disposable cutlery and condiments in individual packages and paper napkins) if the food is to be consumed on the premises.
6*. Impose a five cent tax on bags given out at retail establishments, require signs alerting customers to this, and require that reusable bags be sold.
7*. Alternatively, give retail customers a 5 cent discount for using their own bag (shopping bags, cleaning bags, et. al.) or a reusable box which is offered for sale for 45 cents.
8. Require, or alternatively provide tax incentives for large retailers to make applicable products (e.g., grains, detergents, liquid, etc...) available in bulk.
9*. Require, or alternatively provide tax incentives for retailers providing a minimum percentage of retail shelf space to be set aside for products in refillable/returnable packaging -- this could be expanded to include bulk packaged products and concentrates. (This has also be proposed by a New Hampshire representative.)
10. To discourage wanton remodeling and destruction of otherwise serviceable building exteriors and interiors, and the creation of demolition waste, tax building construction materials (2 cents) and, alternatively (5 cents) per dollar, and construction permits ($200) and, alternatively, ($1,000). Exempt construction materials purchased solely in small quantities and for purposes of repairing or replacing worn building materials.
11*. Require all producers and retailers to accept for recycling, reuse, and/or disposal all returned transport packaging. Require that the consumer can leave all packaging material at the point-of-sale. Require that retailers accept all used packaging materials returned by the consumer.
12*. To discourage disposables, require a tax of (3 cents) and, alternatively, (10 cents) on all disposable products with an exemption for products with a manufacturer's warrantee of at least three years or if manufacturer has an established program to take products back for reuse or recycling. (Disposable means those products which replace products which are reusable, washable, repairable, and/or refillable.)
13. Require that Sunday newspapers be available for sale by the section.
14. Require that phone companies issue phone books on an 18 month basis.
15*. Require a tax of (25 cents) and, alternatively, ($1) on each product which contains parts which are not removeable, serviceable, replaceable, or repairable at facilities in the local area. ("Parts" includes spare parts as well as items like batteries) (Formulate durability standards/design for repairability (e.g., minimum warranty standards, availability of spare parts) for certain products (e.g., double-sided copiers, electronics, appliances).
16*. To reward durable products and reusable packaging, establish a tax credit of (5 cents) and, alternatively, (10 cents) for products and packages which can be refilled in existing programs, recharged by consumer, with at least 50% recycled content, and designed for easy repair (component parts replaceable by consumer) and for products which encourage waste prevention (e.g., canvas bags, double-sided copiers)
17*. Institute a tax credit for companies which install equipment which reduces consumption of nondurable products (dishwashers, double-sided copiers, washing machines, etc..) and which offer services which reduce use of nondurable products (diaper services).
18*. To ensure adequate consumer education and implementation of source reduction, require municipalities to run
- Public Service ads (50 per month, all media);
- Subway, bus, and commuter rail ads (one message per month, one ad per car);
- billboard ads (50 per month);
- leaflets in utility bills (2 campaigns per year);
- free advertising directory for repair, reuse, resale, thrift, etc... shops (issue and distribute one per year via mail and/or via phone company).
19. Explore the effect of collecting a nominal fee from shops to cover costs.
20*. Require that waste reduction handbooks providing less toxic alternatives to household hazardous wastes, and less voluminous alternatives to nondurables and packaging be provided to all.
21*. To enhance consumer education and encourage sound purchasing decisions, require manufacturers to label products for warrantee period and provide information to purchaser on where products can be repaired (if such repair is not nominally available as shoe repair and watch repair typically are)
22. To ensure schoolchildren are educated early, require that waste prevention is taught as a special part of the curriculum in grades K-12.
23. To ensure the curriculum is complete, special waste prevention curriculum as part of science instruction -- which grades, what length of time, curriculum content?
24. To ensure Source Reduction is integrated into the curriculum, specify methods of integration of SR material into other, nonscience, classes (e.g., math problems, civics lessons, geography - natural resources and environmental issues
25*. To assist consumers in environmental purchasing, require shop owners label items with long warrantee periods, refillable, rechargeable, and reusable items, bulk packaged items, concentrates. Use a universe of labeling options. Model with reasonable participation estimates.
26. Institute a system of block and large building volunteer captains who are trained by DOS to disseminate information to fellow tenants and residents about waste prevention.
27* Require municipalities to adopt policies and procedures including the following:
1 Procurement policies promoting waste prevention (applied to all purchases of state and local government, their contractors, grantees, etc...) including at a minimum, products with extended warrantees, having materials delivered in reusable containers, and purchasing uniform equipment (one, well-made brand and model, for each discrete need, which, if one breaks down it is used as the source of spare parts to repair the others).
2 Institution of the "model office" concept in all offices based on a waste audit mechanism (applied to all state and local government offices, contractors, grantees, etc...)
28*. To ensure that government programs promote waste prevention aims, require that the City provide economic incentives for or actually operate programs such as the following:
1 Reuse Centers -- Collection, Resale/reconditioning/swap shop/repairs of bulk items, electronics and appliances, clothing, furniture
2 Awards for superior products and packaging innovations (to encourage industry R&D of better packaging and products)
29. Require the State Department of Economic Development (DED) to issue annual reports on how to reduce the weight and volume of packaging and on how to replace disposable products with reusable ones.
30. Require State DEC to make available to local sanitation districts sets of data on common materials and bibliographic references on materials and waste prevention/reduction, and require DEC to develop a booklet with model scenarios and plans for different types of municipalities.
31. Require NYSDED to offer expertise in the form of a handbook on how to implement waste prevention to all businesses.
32*. Require that tax credits be provided to businesses which maintain and/or repair or refurbish durable products.
33*. Require use of reversible envelopes for utility bills.
34*. Support federal legislation to require that all generators of junk mail be required to send a prepaid postcard requesting removal of addressee from the mailing list be sent with all catalogs, flyers, solicitations, etc....
35*. Support federal legislation to require that all generators of junk mail be required to pay for return postage for all returned junk mail.
Toxicity - Related Initiatives
36. To discourage toxics in packaging via consumer education, require that manufacturers label composition of package with constituent and percent of the following pollutant precursors (nickel, cadmium, mercury, lead, manganese, chromium, arsenic, titanium, copper, beryllium, cobalt, silver, gold, radioactive elements, iron, chlorine, fluorine, sulfur, and nitrogen)
37. To discourage toxics in packaging, require a tax of (2 cents) and, alternatively, (5 cents) be assessed for each package containing any of the following pollutant precursors (nickel, cadmium, mercury, lead, manganese, chromium, arsenic, titanium, copper, beryllium, cobalt, silver, gold, radioactive elements, iron, chlorine, fluorine, sulfur, and nitrogen)
38. To discourage toxics in products, require manufacturers to label composition of products with constituent and percent of the following pollutant precursors (nickel, cadmium, mercury, lead, manganese, chromium, arsenic, titanium, copper, beryllium, cobalt, silver, gold, radioactive elements, iron, chlorine, fluorine, sulfur, and nitrogen)
39. To discourage toxics in products, require a tax of (2 cents) and, alternatively, (5 cents) be assessed for each product containing more than 1% sum total of the following pollutant precursors (nickel, cadmium, mercury, lead, manganese, chromium, arsenic, titanium, copper, beryllium, cobalt, silver, gold, radioactive elements, iron, chlorine, fluorine, sulfur, and nitrogen). Exceptions would include products with a manufacturer's warrantee of at least three years or if manufacturer has an established program to take products back for reuse or recycling.
40. Formulate a definition for "egregious packaging" and draft model legislation banning it.
41. To ensure reductions of pollutant precursors in packaging and products, expand the scope of CONEG law, which requires phase-out of certain constituents in packaging, to include more metals in addition to the cadmium, mercury, lead, and chromium already required (e.g., nickel, manganese, arsenic, titanium, copper, beryllium, cobalt, silver, gold, radioactive elements, iron, chlorine, sulfur, nitrogen and any other significant pollutant precursor). Also include not only packaging but also products in the requirements. Also increase the scope of the CONEG provisions to phase-out within five years rather than phase-down these toxic precursors.
42*. To assist consumers in environmental purchasing, require shop owners to label items such as non-toxic cleaners and other nontoxic household items which are substitutes for items normally considered hazardous wastes. Use a universe of labeling options. Model with reasonable participation estimates.
Recycling - Related Initiatives
43*. Require auto manufacturers to charge a deposit on cars and take back discarded cars for recycling.
44*. Establish a virgin materials use tax (this would benefit both reduction and recycling efforts of both packaging and products)
45. To discourage multi-material packaging, require a tax of (3 cents) and, alternatively, (10 cents) for each material in each package containing more than a single material.
46. Prohibit the sale of multi-material containers with the exception of those containers with removable caps made of a different material.
47. Issue all householders that wish to compost their kitchen and/or garden waste a free composting container complete with worms and instructions for vermicomposting under the sink.
48. To assist consumers in environmental purchasing, require shop owners label items with recycled content packaging and recyclable materials. Use a universe of labelling options. Model with reasonable participation estimates.
49. To reward durable products and reusable packaging, establish a tax credit of (5 cents) and, alternatively, (10 cents) for products and packages which can be recycled in existing programs at a rate of 50% or more.
50. Institute a tax credit for companies that install equipment which recovers a "usable material".
51. Model the effect on recycling of publishing a frequently updated list of secondary materials, costs, and sources, where available.
52*. Require that products labeled "recycled" state clearly the percentages of pre-consumer and post-consumer waste content.