Is it necessary to have a documented 3 R recycling plan in addition to measures?

[Cheryl]

We have a 3 R program running at work with the recylce containers out for paper, bottles and cans. We do not have any controled procedures the information is contained in the operators job description. As well we have not identified the 3 R's as one of our significant aspects.

For certification purposes is it necessary for us to have a documented 3 R plan in addition to measures? At present the town picks up our recycling material at the curb side.

[Dean P.]

Hi Cheryl,

I would think that your 3R program should be considered in your aspects, but not necessarily significant (that is up to you). You obviously are generating solid waste, and the fact that you are recycling them makes it a positive impact on the environment (diversion from landfill). Make sure you get credit for something you are doing right!!

As for including them as a documented plan, there are two ways to look at this. If you have set an objective and target for solid waste reduction, then this would most definitely become part of your environmental managment program. Again, get the credit for it. If you do not have this (or anything related to it) as an objective and target, then having it as part of your procedures / work instructions is suitable under 4.4.6 - Operational Control. Do what you say, say what you do.

Keep in mind though, in Ontario we are mandated to peform a solid waste audit (O. Reg 102) and have a solid waste reduction plan (O. Reg 103), both of which must be updated on an annual basis. Not too many companies know about this requirement. If you have a Canadian auditor, and he is on the ball, he will check to see that you have this plan documented, and could audit it under 4.3.2 - Legal and Other. Let me know if you have any questions about this requirement.

[fireman]

Cheryl & Dean,
Just wanted to add my two cents, this is my first posting, as I am new to this media. Anyways, I have to agree with Dean on all accounts. I also included recycling of office waste on my Aspects Assessment (that's what I called my Aspect FMEA doc) but it indicated a positvie impact.

Dean, what I wanted to know was how detailed the waste stream audit had to be. I identified both O.Regs when searching out my legal and other requirements. I haven't completed anything with them as of yet. Any insight would be appreciated.

Fireman
Robert

[Dean P.]

Fireman,

Fortunately, these two regulations (102 and 103) are probably the two least-enforced regulations out there. Even if the MOE came in and found that you had done nothing, they would probably only mention it to you. The basis of the regulation is to look at your waste streams and put a recycling (waste reduction) program in place. This is where the blue box craze stemmed from several years back.

As for the amount of detail, it really depends on your waste streams. Our facility has 600 employees, and produces all sorts of solid waste from our plastic molding shop, our 3 paint lines, as well as our assembly area. We just completed a 3 day waste audit by a consultant (also called 'dumpster diving') that cost us ~$3500 CDN. This will give us a very detailed report on how much waste we are generating in a year from each individual department, broken down by the waste type (cardboard, paper, plastic, shrink wrap, pop cans, bottles, labels, tape, etc.). Every single item is documented and weighed. Once we have this report, we will probably update it ourselves over the next few years.

You can get away with doing a general audit yourself (estimating the amount of cardboard, paper, etc.) and set your plan based on this, it's up to you. We found that we had a lot of room for improvement, so the cost of the audit would easily be recovered by our reduction efforts. Your waste hauler (Canadian Waste, BFI) should also be able to help you with this, give your rep a call.

[Dean P.]

And by the way, welcome to the Cove!!

[Cheryl]

We have identified solid waste as a significant aspect but we have not included what I classify as our 3 R program (cans, bottles, paper). Presently our solid waste is defined as scrap metal, this is picked up and weighed, we have set objectives and targets against this, but not for our cans, bottles, & paper recycling since this is a curb side pickup conducted through our township.

Can the waste audit be performed through internal auditors or do you recommend we hire experts to conduct annual audits and filing of reports?

[Sam]

Cheryl,
If you have complied with 4.4.1 and feel there is no need for additional procedures, then ,IMO, an additional procedure would not be required for certification.

[Cheryl]

Hey Dean, looks like you where answering as I was posting, disregard my earlier post - you have answered my question.