Contamination in Commingled Recycling Systems Standards & Guidelines Initiative
U.S. EPA Region 10 convened the Contamination in Commingled Recycling Systems Standards & Guidelines Initiative to develop regional solutions to the growing problem of contamination in commingled recycling systems.
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On July 11, 2007, the Contamination in Commingled Recycling Systems Standards & Guidelines Initiative stakeholders met in Seattle, Washington to kick off their workgroup. The workgroup’s vision was to develop standards and guidelines for commingled recycling systems that will reduce cross-contamination of recycled materials, increase the quality and quantity of materials recycled, and capture the highest percentage of materials that are intended to be recycled.
To accomplish its vision, the workgroup broke into three subgroups. The Standards & Guidelines Subgroup drafted processing goals for Material Recovery Facilities (MRFs) and collection guidelines for collectors of commingled materials. The Evaluation Subgroup developed a protocol and system for evaluating whether the processing goals and collection guidelines are being met. The Marketing Subgroup developed tools to ensure that the standard and guidelines are incorporated into contracts, purchasing, policy, and permitting.
This Initiative was a result of the Washington Beverage Container dialogues. The dialogues convened to address how to increase beverage container recycling in Washington State. It resulted in a request for proposals to increase recycling through incentives, as well as the Contamination in Commingled Recycling Systems Standards & Guidelines Initiative to address contamination of recyclables in commingled systems.
The timeframe for this work was approximately one year. The first stakeholder meeting was held in July 2007, and the final stakeholder meeting was held in September 2008. Stakeholders involved in the process included collectors, MRFs, mills, non-governmental organizations, and local and state government agencies. The U.S. Environmental Protection Agency Region 10 served as a convener.
In September 2008, EPA Region 10 handed off deliverables to states, Oregon and Washington, for their implementation processes. The Oregon Department of Environmental Quality and Washington State Department of Ecology will be leading individual implementation processes (see Next Steps).
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What are the issues?
Commingled, or single stream, recycling systems involve the mixing of recyclable materials for the purpose of efficient collection. Depending on the recycling program, commingled recycling systems may include just a few recycled materials or a wide range. A commingled system allows customers to put all recyclables into the same cart or bin with no sorting. These commingled recyclables are collected, loaded into a single truck compartment, and transported to a processer or a material recovery facility (MRF). The MRF is tasked with sorting all the recyclables back into high quality feedstock streams, with limited contamination by outthrows and prohibitives.
While the move to commingled recycling systems has a number of advantages, including increased participation in recycling programs by households and businesses and reduced collection costs, there are significant disadvantages. In particular, commingled recycling systems cause problems for manufacturers of products with recycled content and result in losses of collected recyclable materials, thus preventing the full environmental benefit of recycling to be realized.
In the report, Single Stream Recycling Best Practices and Implementation Guide (PDF) (104 pp, 1.3MB, About PDF) Gertman and Kinsella note several challenges facing manufacturers as a result of commingled recycling systems, including:
- Poor quality recovered materials that they must use as production feedstocks;
- Reduced operating and energy efficiencies from poorly sorted materials that include many contaminants to their manufacturing systems;
- Dramatically increased internal costs because poorly sorted materials demand new and upgraded feedstock cleaning systems, increased maintenance, and more frequent equipment repair and replacement;
- Lost access to recyclables needed for manufacturing when they are sent to the wrong types of manufacturing mills;
- Increased raw material costs to replace those too contaminated to use; and
- Increased costs from landfilling unusable materials included in the bales bought to make recycled products.
Several assessments of local MRFs have documented the loss rate of recyclables in commingled systems. The 2006 King County MRF Assessment (PDF) (76 pp, 380K) found that 7,000 tons of recyclables were lost from Puget Sound MRFs as residual and additional recyclables ended up in the wrong product stream (e.g., 4,200 tons of non-paper recyclables in newspaper).
Loss rates are of concern because the environmental benefit of recycling, particularly in the Pacific Northwest, does not derive from reduced landfilling but the reduction of virgin material inputs. More precisely, most “upstream” impacts are larger than “downstream” impacts. Upstream impacts may include, for example, the energy use, habitat impacts, and pollution and wastes resulting from the extraction and harvesting of raw materials. Downstream impacts, on the other hand, may include the leachate, methane, and other air emissions from landfills.
U.S. EPA’s Waste Reduction Model (WARM) allows comparison of different waste management options in terms of energy units, million BTU. For example, recycling PETE or PET rather than landfilling it saves approximately 53 million BTUs per ton, which is equivalent to nine barrels of oil or 429 gallons of gasoline. Recycling aluminum cans rather than landfilling is an even greater energy savings – 207 millions BTUs per ton, which is equivalent to 36 barrels of oil or 1,665 gallons of gasoline.
Pacific Northwest MRFs are motivated to do quality sorting to meet the demands of their customers, but the quality demanded varies in the global marketplace. Export markets often pay more than domestic markets and for lower quality materials. MRFs must also operate efficiently. They have spent millions on sorting equipment and must efficiently utilize that equipment to survive financially. There is strong pressure to speed up the sort line and to reduce costs by minimizing sorters. Despite these pressures, the compelling environmental benefits of recycling warranted a stakeholder process focused on increasing recovery rates.
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- Vision Statement
- Mission Statement
- Stakeholder Meetings
Stakeholders involved in the process include collectors, MRFs, mills, non-governmental organizations, and local and state government. Organizations represented at some or all of the stakeholder meetings include:
Association of Oregon Recyclers
Blue Heron Paper Company
Clark County, Washington
City of Auburn, Washington
City of Corvallis, Oregon
City of Eugene, Oregon
City of Gresham, Oregon
City of Olympia, Washington
City of Portland, Oregon
City of SeaTac, Washington
City of Seattle, Washington
City of Sedro Woolley, Washington
City of Vancouver, Washington
Deschutes County, Oregon
Douglas County, Washington
Far West Fibers
Garten Services, Inc.
Glass Packaging Institute
Idaho Department of Environmental Quality
Kahut Waste Services
King County, Washington
Nippon Paper Industries
Tacoma Recycling Company, Inc.
Oregon Department of Environmental Quality
Oregon Recycling Systems
Oregon Refuse & Recycling Association
RABANCO | Allied Waste Industries
SP Recycling Corporation
Smurfit-Stone Recycling Company
Solid Waste Association of North America (SWANA)
Washington County, Oregon
Washington Refuse & Recycling Association
Washington State Department of Ecology
Washington State Recycling Association
Washington Utilities & Transportation Commission
Waste Control Recycling
To develop standards and guidelines for commingled recycling systems such that:
(1) Cross-contamination of recyclable materials would be reduced;
(2) The quality and quantity of materials recycled would be increased;
(3) The highest percentage of materials that are intended to be recycled would be captured.
To agree to clear and measurable standards and guidelines that:
(1) Allows governments and other contracting entities to easily and consistently specify that their materials are collected and processed according to the standard and guidelines for haulers and MRFs;
(2) Allows haulers and MRFs to achieve a higher market value by meeting the standard and guidelines;
(3) Increases the overall quantity and quality of material recycled;
(4) Reduces the quantity of recyclable material lost as either outthrow or prohibitive materials in other recycling streams;
(5) Has a consistent measurement and evaluation system that is cost effective and transparent;
(6) Encourages and rewards more effective and efficient collection systems.
Standards & Guidelines
Purpose: To develop draft standards and guidelines for approval by the larger group that does the following:
(1) Clearly defines the acceptable level of contamination for incoming material to MRFs from collection processes or specifies Best Management Practices for collectors of commingled materials.
(2) Clearly defines levels at which materials processed at MRFs are considered not cross contaminated by other recyclable materials and are considered usable for high end products.
(3) Reflects the larger mission of work group.
(1) Determine and use common terminology.
(2) The guidelines and standards should consider employee safety.
(3) The guidelines and standards should establish a procedure for their revision in response to markets.
(4) Draft collection guidelines to present to larger stakeholder group for review and approval. Collection guidelines should clearly define the acceptable levels of contamination for incoming materials and/or specify best management practices for collectors of recyclable materials.
(5) Draft MRF standards to present to larger stakeholder group for review and approval. MRF standards should clearly define levels at which materials processed at MRFs are considered (1) non-contaminated by prohibitives, outthrows, and other recyclable materials and (2) usable for high quality end products.
(6) Draft guidelines and standards that allow adherence to guideline or standard to be measured. Evaluation Subgroup will design evaluation system.
(7) Draft guidelines and standards that can be incorporated into contracts, purchasing, policy, and permitting. Market Value Subgroup will develop and propose a plan to accomplish such incorporation.
Purpose: To develop and propose an evaluation system for standards and guidelines that includes financing, roles, and accountability.
Purpose: To develop and propose a plan to ensure that the standard and guidelines are incorporated into contracts, purchasing, policy, and permitting.
- July 2007
- February 2008
- September 2008
July 2007 – Project Kick-Off
Stakeholders convened to discuss whether they wanted to work together over the next year to develop and implement a processing level standard for Material Recovery Facilities (MRFs) that would reduce the contamination levels leaving the MRF and directly increase the recycling of materials in Washington, Oregon, Idaho, and Alaska. Stakeholders agreed that the quality of incoming materials to MRFs also needed to be considered and collection guidelines developed. Stakeholders drafted and agreed to the vision and mission statements and formed three subgroups to carry out its goals – Standards & Guidelines, Evaluation, and Market Value (name later changed to Marketing Subgroup).
February 2008 – Stakeholder Meeting #2
Stakeholders reconvened to discuss the Standards & Guidelines Subgroup’s work product and launch the next phase of the process, developing an evaluation protocol and marketing tools. The collection guidelines and MRF standard (now processing goals) were discussed and revised for handoff to the Evaluation and Marketing Subgroups.
September 2008 – Final Stakeholder Meeting
In the final meeting of the stakeholder process, stakeholders met to discuss the Evaluation and Marketing Subgroups’ work products. The collection guidelines, processing goals, evaluation protocol, and marketing tools – white paper, fact sheets, and PowerPoint presentation – were approved for handoff to Oregon and Washington’s individual state-lead implementation processes.
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In September 2008, the U.S. Environmental Protection Agency Region 10 handed off deliverables to states, Oregon and Washington, for their implementation processes. The Oregon Department of Environmental Quality and Washington State Department of Ecology will be leading individual implementation processes. Contacts for more information on the next steps for Oregon and Washington implementation are:
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