25 July 2006 Mr Tim Rogers



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AEEMA

25 July 2006

Mr Tim Rogers

Executive Director

Sustainability Programs Division

Department of Environment and Conservation PO Box 644

PARRAMATTA NSW 2124

via email:

Dear Tim


Thank you for meeting with the AEEMA delegation on 5 July. We found the meeting useful in clarifying issues and better understanding the NSW Government's product stewardship priorities.
The purpose of this letter is threefold: to advise you of the major appliance sector's reasoning in choosing not to join at this stage with other sectors such as automotive or other electrical/electronic consumer durables; to provide more information on proportions of potentially hazardous materials in current design major appliances; and to propose a study that will provide valuable necessary information on waste issues associated with these appliances.
Rationale for sector not joining with others
Following our meeting on 5 July AEEMA established a Major Appliances Environmental Working Group in order to provide more focus and a faster response on environmental issues associated with major appliances. The Working Group complements and contributes to the work of AEEMA's Environmental Policy Working Group.
The Major Appliances Environmental Working Group believes this segregation will improve the efficiency of identifying and focusing on the real issues of the major appliances sector. The reason is that, at end-of-life, there are more differences than similarities between major household appliances and adjacent product categories. Comparison of the significant characteristics of major appliances with those of products in the adjacent groups (automomative on one side and other electrical/electronic consumer durables on the other) will demonstrate why this separation is deemed useful:

• Because of their size and weight, major appliances are not cash and carry'. They require special delivery. Similarly scrapped major appliances are not generally transportable by the homeowner. Thus the preferred method(s) of collection is likely to be unique to this sector.

• All the appliances in this sector are too large for disposal in wheelie bins. Hence the requirements for policing illegal dumping are different.

• In contrast with other electric/electronic items, typically only a very small proportion of major appliance plastic is of fire retardant grades. Plastics with fire-retardants are inherently more difficult to recycle than those without. The percentage of them may also have significance in any future waste-to-energy (WTE) process.

• Because major appliances have significant metal content, once they are collected they possess positive scrap value.

• Apart from older designs of washing machine gearboxes (and a very small quantity in refrigerator compressors), appliances do not contain oils.

• Those unfamiliar with the industry find the levels of other substances now deemed hazardous surprisingly low in either historic appliance waste or in current product. One overseas study found it no higher than in average domestic refuse.

• Apart from concrete balance weights and glass items, shredder floc is likely to be virtually all plastic or rubber. This gives it a high calorific value in any WTE project.

• Appliances do not have solid metal parts such as automotive crankshafts or engine blocks etc. This could make it more practical to use a mobile shredder for them in remote locations.

• The companies supplying major appliances have much in common with each other, and are used to working together to deal with common issues such as performance and safety standards and writing and helping formulate water and energy efficiency levels and labelling regimes. They have much less in common with other groups. Thus this existing cohesive grouping is expected to be able to respond much more quickly than would members in a multiple-group approach.



Potentially hazardous materials in major appliances

The level of hazardous substances in major appliances has never been high, although several materials now identified as hazardous have been used in the past.

The attached papers from AEEMA members Electrolux Home Products and Fisher & Paykel provide further information on the level of potentially hazardous materials.
Proposal for an investigation into waste disposal and recycling of major appliances in Australia

AEEMA's Major Appliances Environmental Working Group has concluded that the problem as perceived of end-of-life major appliances is one or a combination of the following three factors:

1. Too many appliances are going to landfill without pre-processing.

2. Shredder floc from major appliances contain unacceptably high levels of substances deemed to be hazardous.

3. The weight/volume of shredder floc going to landfill is unacceptably high.
Before setting out to rectify the perceived problem, it is necessary first to analyse and quantify the above factors.

Anecdotal evidence available to AEEMA suggests that very few appliances go straight to landfill. For this reason it may be practicable to impose a landfill ban to stop the remaining few that do.

Based on their own records, manufacturers of major appliances believe that the hazardous content of appliance shredder floc is likely to be lower than that from items from any other mechanical or electrical sector. The industry has generally set about eliminating substances shown to be hazardous without the need for compelling legislation.

If the issue is an unacceptable weight/volume of shredder flock going to landfill, action should focus on investigating viable ways to reduce it. It may be worth analysing to what theoretical extent any level of partial dismantling or even complete dismantling (at whatever cost) would reduce the quantity of waste being disposed of. Experience with recycling just under one quarter of a million major appliances by one of the companies represented in AEEMA's Major Appliances Environmental Working Group has shown that while various levels of dismantling may increase the price for better segregated recovered metals, most of the remainder still has to be dumped. Data on WTE systems overseas show that while not cheap to construct or operate, they can be built to meet very stringent emission levels and reduce waste volumes by around 90%. The Working Group believes that this option should not be precluded from consideration on purely emotional or political grounds. If such alternatives are not acceptable, it may be that the present quantity going to landfill will need to be accepted.


In order to help clarify the issues raised above, AEEMA proposes that a study be undertaken of the options for recycling of major appliances and the disposal of any resultant waste. The study will fill major gaps in our knowledge of the end-of-life fate of these products. It is proposed that the study determine:

• the quantity of product collected, recycled, land filled and illegally dumped by

type of appliance and region

• the proportion of land filled shredder floc contributed by major appliances as a percentage of the total floc

• the environmental impact of the current disposal of the product including hazardous materials

• opportunities for reducing shredder floc by WTE or other means based on examples in Australia and overseas

• opportunities for waste avoidance

• impact of a landfill ban on major appliances

• options to augment the existing process
A separate paper providing more details on the proposed study is attached.
AEEMA looks forward in particular to the Department's response on the proposed study. Our major appliance suppliers are committed to co-operate in provision of information and other assistance, including financial support of up to $10,000 to make the study a success.
Yours sincerely

Bryan Douglas

DEPUTY CHIEF EXECUTIVE




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