1

A study of the

attitudes and perceptions of Waste Disposal Authorities (WDAs) in the collection and treatment of WEEE from Designated Collection Facilities

CWM: REPIC/2012/FR

Centre for Waste Management,

School of Built & Natural Environment,

University of Central Lancashire

2

CONFIDENTIAL DOCUMENT

Final Report

Client: Repic

Authors: AR Glover, CN Lowe, TJ McDonnell, KS Williams

Executive Summary

This study was commissioned by REPIC and prepared by the Centre for Waste Management (CWM), University of Central Lancashire.

The report summarises the findings obtained from an online survey into the attitudes and perceptions of Waste Disposal Authorities (WDAs) to Waste Electrical and Electronic Equipment (WEEE) collection and treatment. The online survey was made available to WDA officers in England, Scotland and Wales with direct responsibility for Waste Electrical and Electronic Equipment (WEEE) collected at Designated Collection Facilities. A total of 178 WDAs were contacted and the survey achieved a response rate of 44%. The WDAs sampled were representative of Great Britain. The main findings are:-

The majority of WDAs retain operational control of their Designated Collection

Facilities (DCFs) and directly engage Producer Compliance Scheme (PCSs)

to collect and treat WEEE;

In general, the types of contractual arrangements WDAs had for operating

DCFs, did not impact on the answers given in the survey;

The majority of officers spent less that 5% of their time dealing with WEEE;

WDA officers rated the importance of clear defined audit trails and

environmentally sound collection and treatment as a priority when ranking the

importance of services provided by a PCS;

The reports produced by PCSs for the WDA were considered sufficient for the

majority of officers. Areas highlighted for improvement were better information

on the amount of WEEE exported and the amount reused;

Over half of WDA officers had no knowledge as to whether the PCS was

collecting tonnages of WEEE in accordance with their producers obligation;

The majority of WDA officers believed that they had a basic or working

knowledge of the WEEE Directive and the Code of Practice for the collection

of WEEE from DCFs;

WDAs with a direct relationship with their PCS are more likely to be satisfied

with the costs of WEEE compliance;

Many WDAs believe that a lack of household awareness is impacting on

WEEE collection rates. Nearly half of them are considering communication

campaigns to address this.

3

List of Contents

List of Contents .......................................................................................................... 3

List of Figures ............................................................................................................. 4

List of Tables .............................................................................................................. 5

List of Abbreviations ................................................................................................... 5

1.0 Introduction .......................................................................................................... 6

2.0 Methodology ......................................................................................................... 8

2.1 Collation of WDA Database .............................................................................. 8

2.2 Survey Design and Implementation .................................................................. 8

2.3 Overview of WDA Published Strategies to WEEE ............................................ 9

3.0 Results and Analysis .......................................................................................... 10

3.1 Online Survey ................................................................................................. 10

3.1.1 Section 1 About your WDA .......................................................................... 10

3.1.2 Section 2 Knowledge and Understanding .................................................... 17

3.1.3 Section 3 Training ........................................................................................ 27

3.1.4 Section 4 Management of WEEE ................................................................ 29

3.2 Waste Strategies of WDAs ............................................................................. 34

4.0 Key findings ........................................................................................................ 37

4.1 About your Waste Disposal Authority ............................................................. 37

4.2 Knowledge and Understanding ....................................................................... 37

4.3 Training ........................................................................................................... 38

4.4 Management of WEEE ................................................................................... 38

4.5 WDA Waste Strategies ................................................................................... 38

5.0 Conclusions ........................................................................................................ 38

6.0 References ......................................................................................................... 39

7.0 Appendices ........................................................................................................ 41

7.1 Appendix 1: Questionnaire ............................................................................. 41

7.2 Appendix 2 Email text ..................................................................................... 47

1 Initial Contact with Identified WDA ..................................................................... 47

2 Pilot e-mail ......................................................................................................... 47

3 Initial e-mail following receipt of contact information .......................................... 48

4 Follow-up e-mail (no information received from first request) ............................ 48

7.3 Appendix 1 BIS Letter to Local Authorities ..................................................... 50

4

List of Figures Figure 1 Inter-relationships between key components of the DCF - WEEE collection,

recycling and disposal system (McDonnell and Williams, 2010). ........................ 7

Figure 2 Percentage of WDA respondents versus population size serviced ............ 10

Figure 3 Geographical area serviced by WDA respondents ..................................... 11

Figure 4 Working time spent on managing WEEE by WDA officers ......................... 12

Figure 5 Mean reported WEEE tonnages for WDA population size bands ............... 13

Figure 6 Relationships of WDAs in selection of PCS and DCF management .......... 14

Figure 7 Respondents answer to duration of PFI contractual arrangements ............ 15

Figure 8 Respondents answer to duration of contracted waste management .......... 15

Figure 9 WDA level of priority of WEEE compared to overall waste collection ......... 16

Figure 10 Respondents‟ replies to the bearer of cost in WEEE collection ................ 17

Figure 11 Level of understanding of the (recast) of the WEEE Directive ................. 18

Figure 12 Level of knowledge of the Code of Practice (2010) for the collection of WEEE from a DCF ............................................................................................ 19

Figure 13 Level of knowledge of PAS 141 (2011) .................................................... 20

Figure 14 Respondent awareness of PCS collection figures and obligation ............ 21

Figure 15 Satisfaction level (mean) of services provided by the PCS ...................... 22

Figure 16 WDA mean importance of value added value factors provided by ........... 25

Figure 17 PCS provision of sufficient evidence to WDA to prevent illegal ................ 26

Figure 18 Respondents knowledge of PCS safeguards against illegal .................... 26

Figure 19 WDA sources of information and guidance on WEEE .............................. 27

Figure 20 Preferred options in sources of further guidance ...................................... 27

Figure 21 Subject preference for further training or guidance .................................. 28

Figure 22 Frequency of PCS reporting ..................................................................... 29

Figure 24 Additional report information ranked by respondent number .................... 31

Figure 25 Potential impacters on household collection figures ................................. 32

5

List of Tables Table 1 Comparison of population bands of surveyed WDAs against published

statistics of WDAs in England and Wales ......................................................... 11

Table 2 Relationship between PCS contract type and population size of surveyed WDAs ................................................................................................................ 14

Table 3 Knowledge of WEEE obligation collected by PCS selection criteria ............ 21

Table 4 Comparison between PCS contract type and WDA officer satisfaction with reporting ............................................................................................................ 23

Table 5 Comparison between PCS contract type and WDA officer satisfaction with cost ................................................................................................................... 23

Table 6 Comparison between PCS contract type and WDA officer satisfaction with customer service ............................................................................................... 24

Table 7 Comparison between PCS contract type and WDA officer satisfaction with WEEE collection ................................................................................................ 24

Table 8 Potential improvements to PCS reporting ................................................... 30

Table 9 Response to the adoption of measure to increase WEEE collection rates .. 32

Table 10 Response to the adoption of measures to increase WEEE reuse by WDAs .......................................................................................................................... 33

Table 11 Comments from WDAs websites regarding WEEE in their Waste Strategy communications ................................................................................................ 36

Table 12 Reference list of web links to WDAs listed in Table 11 .............................. 36

List of Abbreviations Approved Authorised Treatment Facilities (AATFs)

Approved Exporters (AEs)

Department for Business Innovation and Skills (BIS)

Designated Collection Facilities (DCFs)

Distributor Take-back Service (DTS)

European Commission (EC)

P (probability)

Producer Compliance Scheme (PCS)

Private Finance Initiative (PFI)

tonnes per annum (tpa)

Used electrical and electronic equipment (UEEE)

Waste Disposal Authorities (WDAs)

Waste Electrical and Electronic Equipment (WEEE)

6

1.0 Introduction The WEEE Directive is implemented in the UK through the Waste Electrical and Electronic Equipment Regulations 2006 (as amended). The Directive aims to address the environmental impacts of Electrical and Electronic Equipment (EEE) when it reaches its end of life and to encourage its separate collection, subsequent treatment, re-use, recovery, recycling and environmentally friendly disposal. It also seeks to improve the environmental performance of all operators involved in the lifecycle of WEEE.

The original WEEE Directive 2002/96/EC has been recast and updated with WEEE Directive 2012/19/EU adopted on the 4th July 2012. As a result of the recast and the Government‟s Red Tape Challenge (an initiative aimed at reducing the costs and administrative burdens to business) the UK WEEE system is going through a major overhaul. A consultation document for the new regulations is expected in March 2013.

The UK WEEE Producer Compliance System has suffered from a number of inherent weaknesses brought about by the „must buy‟ approach to evidence. The Department for Business Innovation and Skills (BIS) has stated that they will consult on options to improve the collection of WEEE. They are proposing to move to one PCS or to retain a multiple PCS system with significant changes to the way in which evidence is generated and traded which could include a DCF allocation system.

Despite the current rules on WEEE collection and recycling only one third of arisings in the European Union (EU) were reported as separately collected and appropriately treated in 2012 (European Commission, 2012). The inherent value in WEEE means that there are multiple economic operators and an increased opportunity for leakage from the official system. This study examines what current perceptions are with respect to the above system and how this influences the WDA and PCS contractual arrangements.

Figure 1 shows the inter-relationships between householders, WDAs and PCS schemes financial flows and audit trail of the WEEE system in the UK.

Producers are required to join a PCS to discharge their obligations e.g.

registering as a producer, reporting data on EEE put on the market and

financing the costs of collection, treatment, recovery and disposal of their

obligated WEEE. In the UK there is an open market for PCSs, with over

40 currently in existence;

Distributors (retailers) are required to provide a take-back service to

householders enabling them to return their WEEE free of charge. This can

be through in-store take back, by participating in the Distributor Take-back

Service (DTS) or providing an alternative system for free take-back;

Local WDAs have no direct legal obligations under the WEEE

Regulations. They can register their household waste recycling centres

and transfer stations as DCFs. In practice most local authorities choose to

take advantage of the opportunity to get WEEE collection and recycling

financed by producers. LAs are required to follow the DCF Code of

Practice;

7

Approved Authorised Treatment Facilities (AATFs) and Approved

Exporters (AEs) deal with WEEE arising at DCFs and on behalf of PCSs.

AATFs and AEs issue evidence that WEEE has been received and will

be treated, recycled and recovered in line with the regulations.

Figure 1 Inter-relationships between key components of the DCF - WEEE collection, recycling and disposal system (McDonnell and Williams, 2010).

REPIC Ltd is the UK‟s largest PCS operator with a market share of around 50%. REPIC commissioned the University of Central Lancashire to undertake an independent survey of WDAs to gauge their opinions about the current WEEE system and the authority‟s relationships with their PCSs. The findings will help to inform REPIC‟s activities going forward. The findings also have wider relevance to changes being considered for the WEEE recast and Red Tape Challenge.

8

2.0 Methodology

2.1 Collation of WDA Database

A comprehensive database of staff directly responsible for the management of WEEE within WDAs in England, Scotland and Wales was a key requirement for the project. To achieve this objective use was made of publically available local government information and direct contact with relevant authorities to identify key personnel within each WDA (see Appendix 7.2(1)). Each potential respondent was initially contacted by email in order to verify the accuracy of the database and make the recipients aware of the research project. In cases where there was no response or insufficient information was provided, recipients were contacted by telephone. If this did not produce a valid contact, the WDA was contacted to obtain the contact details of the staff member responsible for the management of WEEE. This process yielded a valid and current (at the time of the study) contact database of 178 WDAs in England, Scotland and Wales.

2.2 Survey Design and Implementation

The WDA survey was designed using the Bristol Online Surveys (BOS) Software and was made available for online completion for a calendar month from the 23rd July to the 23rd August 2012. Prior to release the questionnaire was pre-tested, revised (in collaboration with the industry sponsor) and piloted on eight randomly selected WDAs (5 responses returned). Care was taken in design of the questions to ensure that individuals and WDAs could not be identified from their responses. Ethical approval for the research programme was obtained from UCLan‟s Ethics Committee in advance of the questionnaire being released.

The survey consisted of 28 predominantly closed questions (including several Likert scale-based questions1) divided into 4 sections headed as follows:-

Section 1: About your WDA- This section sought to gather general information about the WDA and the individual respondent including population size and geographical area (limited to specific bands), job title and level of responsibility for management of WEEE. This section also included a key question that determined how the WDA selected its current PCS.

Section 2: Knowledge and Understanding- This contained 8 questions to establish knowledge levels of the respondent with respect to WEEE-related legislation and the role of their PCS. Satisfaction levels with respect to key aspects of PCS provision was also assessed in addition to determining the importance of key value-added factors in PCS selection.

Section 3: Training- This contained 4 questions to determine how respondents accessed information on WEEE, their preferred option for accessing this information and specific areas of information deficiency.

Section 4: Management of WEEE- This section sought initially to determine satisfaction levels with respect to services provided by the PCS before assessing the impact that specific factors had on household WEEE collection figures. Two final questions investigated the measures that WDAs were currently or considering using

1 A Likert scale is a psychometric scale commonly involved in research that employs questionnaires. It is the most widely used

approach to scaling responses in survey research, such that the term is often used interchangeably with rating scale.

9

to increase WEEE collection and re-use rates. The raw data were managed using Bristol Online Surveys and statistically analysed using Minitab release 16. Chi-square tests and T-tests2 were used to statistically investigate selected associations between answers.

A printed copy of the online version of the questionnaire is provided in Appendix 1. All WDAs on the database (excluding the 5 that responded to the pilot survey) were contacted by email (see Appendix 2 for email text) on the date the questionnaire was placed live on BOS and provided with a link to the online survey. A second email was sent out to all potential respondents 2 weeks after the initial email in an attempt to maximise responses.

2.3 Overview of WDA Published Strategies to WEEE

A desk-based study was carried out to ascertain the importance attached to WEEE within published WDA waste management strategies. This was not part of the original project brief but was undertaken to place WEEE in the overall context of a WDA published waste strategy. Ten WDAs were selected randomly and the most recent waste strategies obtained via the authorities website. A word search for “WEEE” and “electronic waste” was performed on the obtained documents and the number of “hits” recorded alongside a brief assessment of the identified text. The search did not extend into lower order documentation which may have been more focused on the operational approach to dealing with WEEE. To further validate the findings the approach was repeated for another ten WDAs (selected by virtue of being the nearest neighbour to one of the original selections). The results are shown in 3.2 Waste Strategies of WDAs.

2 Chi square and T-test are statistical methods to determine if there is a significant difference within a question part by the

different respondent groups. They apply to normally distributed data.

10

3.0 Results and Analysis

3.1 Online Survey

The results are presented sequentially in question order grouped in the four section

headings of the questionnaire (see Appendix 1).

3.1.1 Section 1 About your WDA

Question1 Please indicate the population size covered by your WDA

Figure 2 Percentage of WDA respondents versus population size serviced

To determine if obtained results were indicative of the general trend of population size serviced by WDAs; national government statistics were used to establish the population sizes for WDAs (n=110) in England and Wales (data for Scotland was unavailable). Table 1 compares the population distributions for WDAs from the survey (Figure 2) and data from external Local Authority sources3. The table indicates that those WDAs taking part in the survey were broadly indicative of WDAs nationally. Consequently, the participant WDAs could be treated as being a representative cross section of WDAs in the UK.

3 Population sizes were drawn from local authority web sites (http://lats.defra.gov.uk &

www.direct.gov.uk) A-Z of local councils, accessed 05/04/2012

46%

31%

6%

5%

6% 6%

<200k

200 - 400k

400 - 600k

600 - 800k

800 - 1000k

>1000k

11

WDA Population Bands

(thousand people)

WDA Survey Response

(%)

WDAs in England & Wales* (n=110)

(%)

<200 46 45

200 – 400 31 22

400 – 600 6 12

600 – 800 5 9

800 – 1000 6 11

>1000 6 2

Table 1 Comparison of population bands of surveyed WDAs against published statistics of WDAs in England and Wales

Question 2 Please indicate the geographical area covered by your WDA

Figure 3 Geographical area serviced by WDA respondents

Figure 3 shows that 50% of the WDAs service geographical areas of up to 250 km2. Combined with the result of Question 1 the majority of WDA respondents have population sizes of up to 200,000 in geographical areas of up to 250 km2.

Question 3 What is your job title?

The question invited the respondent to enter their job title into a text box. The list of titles varied across the respondent range with no more than two similar titles appearing. No title entered contained any reference to WEEE or electrical waste. The most common title referred to waste manager or waste in a general context.

34%

16% 14%

8%

14%

8% 6%

< 100 km2

100 - 250 km2

251 - 500 km2

501 - 1,000 km2

1,001 - 3,000 km2

3,001 - 5,000 km2

>5,000 km2

12

Question 4 Please estimate what percentage of your time is spent dealing with the management of WEEE generated within your WDA?

Figure 4 Working time spent on managing WEEE by WDA officers

All respondents spent no longer than 15% of their working time managing WEEE. This suggests that WEEE represents a part of the duties for officers in line with their overall responsibility for the whole municipal waste streams.

Question 5 How long you have had responsibility for the management of WEEE?

The majority (46%) of respondents stated that they had held the responsibility for the management of WEEE for more than 5 years. This indicated that a significant proportion of WDA officers had managed the WEEE waste stream for their WDA since the UK implemented the WEEE Directive 2002/96/EC in January 2007 (BERR, 2007). This is reflected in Q12 & 13 where most WDA officers believed that they have a good working knowledge of the legislation.

Question 6 How much WEEE (in tonnes) was recycled in your WDA in the last

reporting year?

The total tonnage of WEEE recycled by the respondent WDAs (n = 52) was 83,527 tpa. The mean tonnage collected by respondents was 1,606 tpa as compared with a calculated mean tonnage for the 178 WDAs in the GB (excluding Northern Ireland) of 2,040 tpa. Our survey response of 23% would indicate a total GB tonnage of 363,600 t collected through DCFs. This compares with an EA reported number of 378,599 t in 2011.

89%

11%

WDA officers spending < 5%of working time on WEEE

WDA officers spending 5 -15% of working time on WEEE

13

There was no significant relationship (P > 0.05) between time spent dealing with WEEE (Question 4) and the tonnages collected. This indicates that those waste managers with a lower tonnage of WEEE were not spending less time managing WEEE.

Collected WEEE tonnage figures by population band size are provided in Figure 5.

Figure 5 Mean reported WEEE tonnages for WDA population size bands

The mean tonnages reported increased proportionally with population band size with the exception of the 600 – 800 k WDA population size. It is suggested that the figure should be closer to 3,000 tpa for this population band. However, the number of respondents representing this figure is only 5% of the total and therefore anomalies in the collection figures could be adversely affecting the results.

Question 7 Which of the following statements best describes how your WDA selected its current WEEE - PCS?

This question explored the possible contractual permutations in a WDAs selection process of a PCS for the collecting and recycling of WEEE from Designated Collection Facilities. The question took into account out-sourcing contracts to administer DCFs through either Private Finance Initiatives (PFI) and/or external management companies. The results in Figure 6 show that 67% of WDAs retained control in selecting the PCS to collect and treat WEEE from the DCFs in the authority. Of those WDAs in PFI contracts, 33% passed the selection of the PCS to the PFI or external waste management company.

14

Figure 6 Relationships of WDAs in selection of PCS and DCF management

To understand whether the WDAs‟ selection arrangements of a PCS may be related with the population band size, the results of Question 7 were cross-tabulated with the population band size (Question 1).

Table 2 Relationship between PCS contract type and population size of surveyed WDAs

The results (Table 2) suggest that for lower population band sizes the trend is for WDAs to retain control of the selection process for the PCS. This is demonstrated in the first two data columns in Table 2 (population band size <200 k and 200 – 400 k). For higher population bands > 400 k the results suggest that WDAs pass selection and control of the PCS to a PFI or external management company. Overall the descriptive statistics suggest there is a relationship between contract type and population size. However, further investigation would be required to determine the factors responsible for this observation.

<200,000 200,001 - 400,000400,001 -

600,000

600,001 -

800,000

800,001 -

1,000,000>1,000,000

WDA is

responsible

for PCS

selection

23 (85%) 11 (58%) 1 (25%) 1 (33%) 0 (0%) 2 (50%)

WDA is not

responsible

for PCS

Selection

4 (15%) 8 (42%) 3 (75%) 2 (67%) 4 (100%) 2 (50%)

47%

20%

15%

18% WDA managed DCF - directcontracted PCS

WDA contracts externallymanaged DCF- directcontracted PCS

PFI managed DCF & PCScontract

Externally managed DCF &PCS contract

15

Question 8 If the WDA has entered into a PFI agreement with an external Waste Management Company how many years are left before this agreement expires?

Figure 7 Respondents answer to duration of PFI contractual arrangements of DCFs

The response to this question supports the findings of Question 7 in the number of respondents engaged in PFI contractual arrangements for the running of their DCFs. The respondents who did not answer would suggest that they did not know how long the PFI contract had to run or that they had no direct contractual responsibility. The respondents who entered not applicable suggest that their WDAs were not engaged with PFI contracts.

Question 9 If the WDA sub-contracts its waste management responsibilities to an external Waste Management company how many years are left before this agreement expires?

Figure 8 Respondents answer to duration of contracted waste management of DCFs

0

5

10

15

20

25

30

35

40

Did NotAnswer

NotApplicable

5 yrs 5-10 yrs 11-15 yrs 16-20 yrs 20-25 yrs

Re

spo

nd

en

t n

o.

0

5

10

15

20

25

30

Did notAnswer

NotApplicable

0-2 yrs 3-4 yrs 5-6 yrs 7-8 yrs 9-10 yrs >10

Re

spo

nd

en

t n

o.

16

The response to this question supports the findings of Question 7 in the number of respondents engaged in external contracts with waste management companies for the running of their DCFs.

It suggests that any respondent who did not answer or entered not applicable was not engaged with external waste management companies for WEEE.

Question 10 What level of priority does your Waste Disposal Authority give to WEEE collection with respect to overall waste collection responsibilities?

Figure 9 WDA level of priority of WEEE compared to overall waste collection

The majority of respondents (n=63) considered the WEEE collection aspects of their waste management activities as having a high priority or very high priority in relation to the overall waste stream. As the WEEE Directive was transposed into UK regulations in 2006 and the WEEE collection scheme started in January 2007, it is suggested that the system is relatively new compared to other historical waste stream administration. Therefore attention to satisfactory operation of WEEE collections will be higher as the system continues to evolve and settle

5%

44%

40%

11%

Low priority

Medium priority

High priority

Very high priority

17

3.1.2 Section 2 Knowledge and Understanding

Question 11 In your opinion which of the following sectors currently bears most of the cost for WEEE collection and treatment?

Figure 10 shows that that 45 % of WDA officers identified producers and the electrical equipment supply chain as being responsible for the collection and treatment of WEEE, however, 55 % of respondents identified other stakeholders as being responsible for costs. Whilst producers are ultimately responsible for costs, care should be exercised in the interpretation of the results. The interpretation that the consumer ultimately pays for the recycling through higher new products costs cannot be dismissed.

Interestingly, 16% of WDA officers believe that they are picking up the costs. This should not be the case as producers pick up the costs of treatment and the DTS is designed to pick up the costs of DCF site improvements. It should also be noted that 20% believe it is the PCSs that are responsible for the costs.

Further analysis would be required to establish that the question was understood and answered objectively.

Figure 10 Respondents’ replies to the bearer of cost in WEEE collection and treatment

45%

16%

16%

20%

3% Producers, retailers anddistributors

Local Authorities

Consumers

Producer compliance schemes

Others (please specify)

18

Question 12 What is your level of understanding with respect to the recently adopted (2012) recast of the WEEE directive?

Figure 11 Level of understanding of the (recast) of the WEEE Directive 2012/19/EC

The results show that 83% per cent of respondents believed that they had either a basic knowledge or full understanding of the recast of the WEEE Directive 2012/19/EU. However, even though 17% of respondents were unaware of the recast, this may be understandable as the new WEEE Directive was only adopted on the 4th July 2012.

17%

81%

2%

Unaware of the recast

Basic or working knowledge ofthe recast

Fully understand the recastand implications for WEEEcollection targets

19

Question 13 What is your level of understanding with the respect to the Code of Practice (2010) for the collection of WEEE from DCFs distributed by Department for Business Innovation and Skills (BIS)?

Figure 12 Level of knowledge of the Code of Practice (2010) for the collection of WEEE from a DCF

Figure 12 shows that 76% of respondents had a basic or working knowledge of the Code of Practice. With only 8% reporting that they were unaware of the Code of Practice. Encouragingly 92% reporting they had knowledge of the Code and/or understood the implications for the WDA.

The Code must be adopted by all PCSs and operators of DCFs. It sets out minimum requirements for the arrangements between DCF operators and the PCS. Where a LA has placed day to day running of a DCF in the hands of a third party, the LA remains responsible for the operation of the site for the purposes of the Regulations.

This could indicate a training need to bring all WDAs knowledge up to a level between a good working knowledge and full understanding the code.

8%

76%

16%

Unaware of the Code

Basic or working knowledge ofthe Code

Fully understand the Code andimplications for the WDA

20

Question 14 What is your level of understanding with respect to PAS 141: 2011

Reuse of used and waste electrical and electronic equipment (UEEE and WEEE)

publicly available specification?

Figure 13 Level of knowledge of PAS 141 (2011)

To meet the requirements of the Code of Practice (2010) in relation to re-use of whole items of WEEE, operators of DCFs and PCSs must follow section 16.6 and section 19.6 respectively in ensuring systems are in place to promote the re-use, refurbishment or repair of WEEE items. The establishment of a standard to ensure that WEEE is refurbished and repaired to an auditable standard is defined in the adoption of PAS141 (BSI, 2011). The survey showed that 32% of the WDA officers were unaware of the re-use standard. However, care should be exercised in the interpretation of the result as the Code of Practice does not specifically mention PAS141 but does require that DCF operators are engaged in facilitating systems to promote the re-use of WEEE. For reporting and targets, it would be beneficial if the code of practice stated that re-use is undertaken at facilities that are AATFs where evidence can be generated.

32%

67%

1%

Unaware of PAS 141

Basic or working knowledgeof PAS 141

Fully understand PAS 141and its implications for re-use

21

Question 15 To the best of your knowledge which of the following statements best describes the status of your PCS with respect to obligated WEEE collection figures?

Figure 14 Respondent awareness of PCS collection figures and obligation

Figure 14 shows that 51% of respondents had no knowledge of whether the amount of WEEE collected met the WEEE collection and treatment evidence required by the PCS to meet the obligated targets of their producer members.

To establish if lack of knowledge was influenced by the relationship that the WDA has with its PCS, this survey question was cross tabulated with Question 7 (best description of how the WDA selected its PCS). The categories of Question 7 have been amalgamated as shown in Table 3.

PCS collects less than its obligated WEEE

PCS collects only its obligated WEEE

PCS collects in excess of its obligation

Don‟t know Totals

WDA is responsible for PCS selection

5 (14%) 10 (28%) 7 (19%) 14 (39%) 36

WDA is not responsible for PCS Selection

0 (0%) 3 (15%) 4 (20%) 13 (65%) 20

Table 3 Knowledge of WEEE obligation collected by PCS selection criteria

Statistical analysis of the results suggests that there is no significant influence (Chi Square = 5.502, Probability > 0.05) of contract type on a WDA‟s knowledge of its PCS obligated WEEE collection tonnage. Due to the low frequencies of expected

8%

21%

20%

51%

PCS collects less than itsobligated WEEE

PCS collects only its obligatedWEEE

PCS collects WEEE in excessof its obligation

Don't Know

22

counts in 4 cells care needs to be taken in interpreting this result. However, it does appear that a greater proportion of WDAs with direct contracts have a greater knowledge of their PCS‟s requirements.

These findings are particularly interesting in view of activity recently undertaken by BIS to improve transparency regarding obligated tonnages. To this end, BIS have published tables to show which PCSs are in balance and which are under or over collecting. BIS has written to LAs (see Appendix 7.3) outlining a number of issues which they will wish to consider in selecting a PCS – particularly focusing on service quality, treatment standards, clear audit and financial trails, and provision of data – all issues which this survey has demonstrated are important to WDAs.

Question 16 Please indicate how satisfied you are with the following services provided by your PCS?

Survey Question 16 (a-d) invited the WDA to express a satisfaction level of the service provided by their PCS. This ranged from (Very Unsatisfied) to (Very Satisfied) together with a non-applicable category for WDAs with no direct contact with the PCS servicing the DCF sites. The PCS services were:-

Reporting;

Cost;

Customer Service;

WEEE Collection.

The mean levels of satisfaction are shown in Figure 15.

Figure 15 Satisfaction level (mean) of services provided by the PCS

(Note the services provided have been arranged into an ascending order of mean satisfaction)

Generally, the mean response level showed a relatively high level of satisfaction across all the service categories. To determine if the level of satisfaction with the

1 2 3 4 5

Cost

Reporting

Customer service

WEEE collection

1 = very unsatisfied 5 = very satisfied

satisfaction factor mean value

23

service provided was influenced by whether the WDA was responsible for the PCS selection, Question 16 was cross tabulated with Question 7 (best description of how the WDA selected its PCS). Please note categories for Question 7 and Question 16 (a-d) have been amalgamated to allow for statistical analysis.

16a Reporting

N/A Very

unsatisfied /Unsatisfied

Neither Very satisfied

/Satisfied Total

WDA is responsible for PCS selection

7 3 (8%) 1 (3%) 33 (89%) 44

WDA is not responsible for PCS Selection

1 1 (8%) 0 (0%) 11 (91%) 13

Table 4 Comparison between PCS contract type and WDA officer satisfaction with reporting

Low frequencies of expected counts in 5 cells makes statistical analysis

inappropriate but descriptive statistical output (on respondents who thought that the

question was applicable) suggests that WDA contract type has no influence on

satisfaction with respect to PCS reporting which is generally high.

16b Cost

N/A

Very unsatisfied /Unsatisfied

Neither Very satisfied

/Satisfied Total

WDA is responsible for PCS selection

9 2 (6%) 4 (13%) 25 (81%) 40

WDA is not responsible for PCS Selection

8 0 (0%) 4 (36%) 7 (64%) 19

Table 5 Comparison between PCS contract type and WDA officer satisfaction with cost

Low frequencies of expected counts in 4 cells makes statistical analysis

inappropriate but descriptive statistical output suggests that satisfaction with PCS

cost maybe higher in WDAs who are directly responsible for PCS selection. 81% of

WDAs with a direct contract with a PCS were satisfied with PCS costs compared

24

with 64% in WDA‟s with no control over PCS selection. These percentage figures

only include those who considered the question applicable.

16c Customer Service

N/A

Very unsatisfied /Unsatisfied

Neither Very satisfied

/Satisfied Total

WDA is responsible for PCS selection

0 2 (5%) 3 (8%) 33 (87%) 38

WDA is not responsible for PCS Selection

7 0 (0%) 2 (17%) 10 (83%) 19

Table 6 Comparison between PCS contract type and WDA officer satisfaction with customer service

Low frequencies of expected counts in 5 cells makes statistical analysis

inappropriate but descriptive statistical output suggests that satisfaction with PCS

customer service maybe marginally higher in WDAs who were directly responsible

for PCS selection. It is important to note that 7 WDAs without direct responsibility for

PCS selection indicated that this question was not applicable as they were unlikely to

have direct contact with the PCS.

16d WEEE Collection

N/A

Very unsatisfied /Unsatisfied

Neither Very satisfied

/Satisfied Total

WDA is responsible for PCS selection

1 1 (3%) 2 (5%) 33 (91%) 37

WDA is not responsible for PCS Selection

10 0 (0%) 3 (27%) 8 (72%) 21

Table 7 Comparison between PCS contract type and WDA officer satisfaction with WEEE collection

Low frequencies of expected counts in 5 cells makes statistical analysis

inappropriate but descriptive statistical output suggests that satisfaction with PCS

WEEE collection maybe higher in WDAs who were directly responsible for PCS

selection. It is important to note that 10 WDA‟s without direct responsibility for PCS

25

selection indicated that this question was not applicable as they were unlikely to

have direct contact with the PCS.

Whilst differentiation between satisfaction levels between those WDAs with direct

contacts and those without is not significant; it is interesting to consider this in light of

the potential for the UK to move to a DCF allocation system. Such a system would

remove the requirement for a WDA to choose a PCS with their tonnage allocated to

a PCS nationally. These results could indicate that this would not be a significant

issue for WDAs in terms of satisfaction with PCSs overall.

Question 17 After operational and financial considerations have been taken into

account, on a scale of 1 to 5 (where 1 is not important and 5 is very important)

please rate the importance of the following value-added factors when choosing a

WEEE, PCS.

The results of Question 17 are ranked in Figure 16

Figure 16 WDA mean importance of value added value factors provided by PCS

It is clear that the most important added value factors from the WDA‟s perspective were clear confirmed audit trails and the environmental credentials of the PCS.

1 2 3 4 5

PCS is partially funded by trading WEEEevidence notes

Not for profit status

Retention of existing re-use, collection andtreatment partners

Direct relationship with the scheme thatfunds the recycling

PCS is fully funded by producers

Where feasible local treatment of WEEE

PCS that actively encourages re-use withpartner

Guaranteed UK based treatment andrecovery

Support for community based collectionschemes

Environmental Credentials

Clear confirmed audit trail

importance factor 1 = not important 5 = very important

importance…

26

Question 18 “Does your PCS provide you with sufficient evidence to ensure that safeguards are in place to guarantee that there is no illegal export of WEEE to developing countries”?

The majority of respondents 77% replied that there were sufficient safeguards in place to assure no illegal export of WEEE Equipment.

Figure 17 PCS provision of sufficient evidence to WDA to prevent illegal export of WEEE

However 23% were uncertain. Question 18 was cross-tabulated with Question 7 to determine whether DCF control and PCS selection had any influence on the respondents who were uncertain. The result is shown in Figure18.

Figure 18 Respondents knowledge of PCS safeguards against illegal WEEE export cross tabulated against DCF contract type

77%

5%

18%

Yes

No

Don‟t Know

27

Figure 18 suggests that the contract type does not have an influence on the uncertain responses as they are distributed across the type of contracts operated by WDAs. It is recommended that care should be exercised in the interpretation of the results and should be the subject of further investigation if required. However, WDAs with a direct contract with their PCS were more likely to answer yes.

3.1.3 Section 3 Training

Question 19 Which of the following do you use to obtain further guidance and/or information on WEEE

Figure 19 WDA sources of information and guidance on WEEE

Question 20 Please indicate your preferred option for gaining further guidance and/or information on WEEE

Figure 20 Preferred options in sources of further guidance on WEEE

0 20 40 60 80 100

Webinars:

Other :

On-line Forums:

Trade Magazines:

Producer Compliance Scheme:

External Workshops and Seminars:

Professional Body Web Sites:

Professional Body Magazines /…

Government Web Sites (e.g. BIS,…

Local Authority Networks:

percentage of respondents

Respondents choice ofinformation sources

0 20 40 60 80 100

Webinars:

On-line Forums:

Trade Magazines:

Producer Compliance Scheme:

External Workshops and…

Professional Body Web Sites:

Professional Body Magazines /…

Government Web Sites (e.g.…

Local Authority Networks:

Percentage of respondents

Respondents preferred choiceon further guidance on WEEE

28

Results from Questions 19 and 20 (Figure 19 and 20) suggest that WDA staff gain information related to WEEE from a broad spectrum of sources but rely on Local Authority Networks and Government web sites for the majority of guidance and information on WEEE. Observed trends in the results suggest that WDA staff are satisfied with their present information sources as preferred information choices (Question 19) are similar to used information sources (Question 20). Third party and unofficial sources of WEEE information tend to rank lower in the results of both questions.

Question 21 Which of the following areas would you benefit from further guidance/training in?

Figure 21 Subject preference for further training or guidance

From the number of respondents (n=56) to this question 73% indicated that they would benefit by being updated on the proposed new WEEE legislation. Forty three per cent indicated that current knowledge on WEEE legislation could be improved by further training. There was an overall positive response to the question on further training/guidance with only 18% of the respondents claiming to have adequate knowledge. It would appear that both WEEE funding and compliance require future initiatives in guidance and training.

0 5 10 15 20 25 30 35 40 45

Other

None - Adequate Knowledge

Storage and Treatment of WEEE

Compliance Scheme Responibilities

Duty of Care (Specific to WEEE)

WEEE Compliance

Funding Opportunities (Specific to WEEE)

Current WEEE Legislation

Proposed WEEE Legislation

29

3.1.4 Section 4 Management of WEEE

Question 22 In addition to waste data flow reports how often do you receive reports from your PCS?

Figure 22 Frequency of PCS reporting

This question reports factual data and should be used in conjunction with Question 23.

Question 23 How satisfied are you with the contents of the reports?

Figure 23 Satisfaction with current reporting systems

83%

5% 2%

10%

Once a month

Once every 3 months

Once every 6 months

Other

15%

14%

71%

Disatisfied or very disatisfied

Neither satisfied or unsatisfied

Satisfied or very satisfied

30

It was found that 71 % of respondents were either satisfied or very satisfied with the present level of PCS reporting. This figure could be increased by the inclusion of a number of those in the neither satisfied nor unsatisfied because it is an expected level of service. Taken together it would appear that the monthly reporting format is acceptable.

Question 24 What Improvements could be made to the PCS reports that you currently receive?

This question asked for changes that could be made to improve reports received from the PCS. For respondents indicating a requirement for more detailed information, they were invited to complete part A (subsection) of this question (Figure 24).

Respondents Percentage Number

More detailed information (please answer part A of this question)

31% 17

Less detailed information 0% 0

No changes – the information provide meets all my requirements

67% 36

Other please specify 2% 1

Table 8 Potential improvements to PCS reporting

Overall the majority of WDA officers indicated that the current reports received from PCSs were satisfactory for their needs and did not require improving. One officer specified that the contractor obtained tonnage reports and therefore it is inferred that further information on the tonnage collected would be an improvement in their case. However of the 31% who indicated further information would be an improvement, the ranking of the type of improvements is shown in Figure 24

The part A question asked “In which of the following areas would you like to see more detailed information?”

31

Figure 24 Additional report information ranked by respondent number

The amount of WEEE exported attracted the highest number of responses followed by amount of re-use. This would suggest that information that is linked to audit trails as demonstrated in “clear confirmed audit trail” question (Figure 16). The ‟other‟ selection (Figure 24) suggested further documentation on destinations and authorised approved treatment facility (AATF) registration numbers.

Question 25 In your opinion please rate the impact that the following factors have on household collection figures in your WDA?

The results for Question 25 are ranked from the factors that have the highest impact on collection figures for WEEE to the lowest. It is clear that, the three highest rated factors are connected to knowledge and awareness in members of the public and DCF staff about collection and segregation of WEEE for recycling (Figure 25)

However the results must be considered on the scale of impacts where 1 = no impact and 5 = significant impact. The highest mean impact scored 3.7 and the least 2.9.

0 2 4 6 8 10 12 14 16

Other

Required WEEE collection obligation of thePCS

The amount of WEEE diverted for re-use

The amount of WEEE exported

Response number

32

Figure 25 Potential impacters on household collection figures

Question 26 Which of the following measures to increase WEEE collection figures is your WDA either currently using or considering implementing in the next 12 months

Measures to increase WEEE collection figures

Currently Using

%

Considering using

%

Not Considering

%

Not Applicable

%

Applications for additional funding from the retailer funded Distributor Take Back Scheme

7 23 57 13

Applications for additional funding from other sources

10 23 57 10

Kerbside Collection of WEEE as part of a Household waste collection service

16 22 52 10

A specialised Household WEEE collection service

13 16 58 13

Public Communication Campaigns for WEEE collection

26 46 22 6

Increased WEEE segregation at Designated Collection Facilities

42 16 29 13

Reward-based Collection Incentive Schemes for householders

5 18 67 10

Specific training for Designated Collection Facility operatives

29 26 33 12

Measures to target collection of WEEE by unauthorised and/or unlicensed parties

3 8 77 12

Table 9 Response to the adoption of measure to increase WEEE collection rates

1.0 2.0 3.0 4.0 5.0

Lack of appropriate facilities

Fly tipping

WEEE donated to charity or sold by…

Retailer take back schemes

Collection of bulky WEEE by unlicensed…

Increased segregation of WEEE at DCFs

WEEE placed in residual containers

Lack of knowledge by householder

impact factor 1 = no impact - 5 = significant impact

impact factor

33

The results of Table 9 suggest that measures for increasing WEEE collections that WDAs were currently using or considering using were focussed on education and awareness for the public such as public communication in campaigns for WEEE collection, increased segregation facilities at DCFs and DCF operator training. Measures that were largely not being considered were reward-based incentives for householders, targeting unlicensed collectors, WEEE kerbside collections and applications for additional funding.

Question 27 Which of the following measures to increase WEEE reuse is your WDA either currently using or considering implementing in the next 12 months

Question 27 Percentage of respondents answering

Currently Using

%

Considering using

%

Not Considering

%

Not Applicable

%

Specific training for Designated Collection Facility operatives

23 38 29 10

Public Communication Campaigns for WEEE re-use

18 49 28 5

Implementation of identification and segregation measures of functional WEEE for re-use at Designated Collection Facilities

22 33 38 7

Promote engagement with re-use partners (e.g. Social Enterprises and Charitable Organisations)

39 35 21 5

Measures to target collection of WEEE by unauthorised and/or unlicensed parties

2 16 71 11

Table 10 Response to the adoption of measures to increase WEEE reuse by WDAs

Measures to increase the amounts of reuse were also focussed on education and training (Table 10) and engagement with reuse organisations. The overall trend would suggest that resource commitment in the current economic climate could be a significant factor directing the adoption or disregard of measures such as targeting unlicensed collectors of WEEE (Table 10) or technical resources in identification of WEEE that could be reused.

34

3.2 Waste Strategies of WDAs

The following listing is drawn from WDA websites detailing their waste strategies. The comment in strategy column reports on any action plans or mention of WEEE.

Waste Disposal Authority

Comments in Strategy Web Ref.

Ayrshire No Mention of WEEE Refer to Zero Waste Scotland 1

Cambridgeshire In glossary:- WEEE Directive Waste Electrical and Electronic Equipment Directive. Quote, “A European directive to limit the disposal of electrical waste”.

Action Number 14 – Legislative Responsibilities, “To implement the WEEE regulations by working with PCSs and developing a procedure for collection and disposal of WEEE – by 31st March 2009”. (Operations Panel)

2

Coventry No Mention of WEEE 3

East Lothian No Mention of WEEE except mention of Repic contract extension

4

Herefordshire No Mention of WEEE 5

Plymouth Report by ENTEC – Pie Chart showing 1% of kerbside collection is either WEEE or Hazardous No other Mention of WEEE

6

Poole Communication campaigns over next 5 years to target specific materials WEEE is on the bottom of a list. Collection strategy review 2013 to include WEEE textiles and batteries.

In document list of applicable legislation WEEE Directive, “WEEE recycling Introduced July 2007. Poole categorise WEEE into 5 types, large domestic white goods non-refrigerated, refrigerated, Fluorescent tubes, TV's and monitors and small electrical items. Insufficient data has been recorded at this present time to make judgement on additional materials”.

Medium term action plan is to provide additional containers for small WEEE and batteries. Poole Waste Strategy Review 2008 – 2018

Gives definition of WEEE and some opportunities e.g. sharing with not for profit organisations and consideration to type of collection bin. Also details WEEE directive and RoHS Final Municipal Waste Management Strategy for Cardiff (Nov.2005)

7

Cardiff Gives definition of WEEE and some opportunities e.g. sharing with not for profit organisations and consideration to type of collection bin. Also details WEEE directive and RoHS

8

Solihull No Mention of WEEE Waste Management Strategy 2010- 2020 9

Telford “The council will provide information to encourage segregation of recyclables, Household Hazardous Waste and Waste Electrical and Electronic Equipment (WEEE) at CRC sites”.

Work with industry to promote the recovery of WEEE and modifying CRC sites to provide segregation facilities.

WEEE implementation A proportion of Waste Electrical and Electronic Equipment (WEEE), such as computers, hi-fi‟s and televisions, must be recovered by industry under the WEEE Directive. Much of this waste is also classified as hazardous.

The Council is therefore likely to work with industry to establish collection services both from householders directly and at the CRCs. The costs of the collection may be met by industry though there is uncertainty over exactly how and what a local authority's share of costs and role in providing services might be.

Municipal Waste Management Strategy 2005-2021. From Waste to Resource

10

35

Thurrock Batteries and small WEEE items represent less than 1% of Thurrock‟s waste. If they were recycled at kerbside it would be very expensive and will have little impact on the recycling rate. The benefit of recycling such items is reducing environmental damage from the chemicals contained within them. Collections will be more economically viable at Civic Amenity sites due to the limited quantities and weight of items involved.

Large items of WEEE, such as televisions, cookers, washing machines, fridges and microwaves are already collected separately from residual waste by the bulky waste service and at the Civic Amenity site.

The WEEE Directive came into force on 1st July 2007 and now all items of WEEE collected or deposited at the Civic Amenity site are stored separately and collected by a contractor operating as part of the Producer Responsibility Compliance Scheme.

A waste strategy graph shows that 0.18% by weight is the fraction of WEEE in Thurrock‟s MSW. This amounts to an annual contribution of 137 tonnes or 0.85 kg per person/year. Collection rates have been targeted to be increased by 5% pa.

Thurrock Council Municipal Waste Strategy 2007-2020

11

South Ayrshire No mention of WEEE

Ayrshire, Dumfries and Galloway Area Waste Plan 2003

12

Cheshire No mention of WEEE

Cheshire Consolidated Joint Municipal Waste Management Strategy Headline Strategy Document

13

Cornwall “Need to collect 4kg WEEE per household per inhabitant “

Refers to Government Review of Waste Policy in England 2011 & Cornwall Waste Local Plan 2003

14

East Renfrewshire Waste Analysis suggest 0.8 kg per household per week and 8.6% of waste collected total Food/Kitchen - Textiles then WEEE. Promotional material produced by PCS Valpak only mention of PCS

Response to Scottish Government Consultation on Regulations to deliver Zero Waste

Zero Waste (Scotland) Regulations 2011

15

Isle of Wight Mention of DCF's and 4kg collection rate

Isle of Wight Municipal Waste Management Plan April 2008 – March 2011

16

Peterborough Mention of WEEE Directive outlining legislative responsibilities. Action 14 requires the WDA to work with PCS for developing a procedure for collection and disposal of WEEE.

17

Portsmouth A SWOT analysis shows WEEE as a threat to the overall Portsmouth strategy.

Veolia Management of Waste in Hampshire

18

Merthyr Tydfil No mention of WEEE

National Strategy - Waste Strategy 2009 – 2050: Towards Zero Waste

19

Somerset No mention of WEEE

National Strategy - Waste Strategy 2009 – 2050: Towards Zero Waste

20

36

Table 11 Comments from WDAs websites regarding WEEE in their Waste Strategy communications

Web Ref. No. e-mail address

1 http://www.south-ayrshire.gov.uk/planning-and-the-environment

2 http://www.recap.co.uk/

3 www.coventry.gov.uk/download/.../id/.../waste_strategy_2008-2020

4 http://www.eastlothian.gov.uk

5 http://www.wasteaware.org.uk/strategy/fullversion2.pdf

6 http://www.plymouth.gov.uk/waste_management_strategy_2007-2030.pdf

7 www.boroughofpoole.com

8 www.caerdydd.gov.uk

9 www.solihull.gov.uk

10 www.telford.gov.uk

11 www.thurrock.gov.uk

12 www.south-ayrshire.gov.uk

13 www.cheshirewestandchester.gov.uk

14 www.cornwall.gov.uk

15 www.eastrenfrewshire.gov.uk

16 www.iwight.com/council

17 http://www.recap.co.uk/information/recap-strategy-2008.asp

18 www.veoliaenvironmentalservices.co.uk

19 www.merthyr.gov.uk

20 www.somerset.gov.uk

Table 12 Reference list of web links to WDAs listed in Table 11

Overall the comments in the waste strategy list in Table 11 suggest that WEEE is not regarded as a key waste stream in the waste strategies of many WDA‟s. Also, this could reflect that WEEE is a small proportion of total municipal waste and the emphasis of implementing landfill directive requirements is a priority. Care should be exercised in the interpretation of this small selection of WDA waste strategies as further information on WEEE waste may be published in other WDA documents.

37

4.0 Key findings

The key findings of the survey are presented in their respective survey sections with the exception of the desk top survey of WDA waste strategies which are presented at section 4.5.

4.1 About your Waste Disposal Authority

The majority of WDAs retained operational control of their DCFs and engage

PCSs directly to collect and treat WEEE;

The management control and selection of a PCS was more likely to be

contracted out when population sizes being serviced by the WDA are greater

than 400,000;

In general, the types of contractual arrangements WDAs had for operating

DCFs did not impact on the answers given in the survey;

In all WDAs surveyed, there were no specific job roles for dealing with WEEE

and the majority of officers spend less than 5% of their time dealing with

WEEE issues. Nearly half of the officers had held the responsibility for dealing

with WEEE for five years;

The time spent by officers on dealing with WEEE was not dependent on the

tonnages collected by the WDA;

Over fifty percent of WDA officers indicated that WEEE collection had a high

priority with respect to overall waste collection responsibilities.

4.2 Knowledge and Understanding

Forty five per cent of WDA officers identified producers, retailers and

distributors as responsible for bearing the cost of WEEE collection and

treatment;

The majority of WDA officers believed they had a basic or working knowledge

of the WEEE Directive and the Code of Practice for the collection of WEEE

from Designated Collection Facilities;

Over half of WDA officers had no knowledge as to whether the PCS was

collecting tonnages of WEEE in accordance with their producers obligation;

WDA officers rate the importance of clear defined audit trails and

environmentally sound collection and treatment as a priority when ranking the

importance of services provided by a PCS;

The reporting system from the PCS was sufficient for the majority of WDA

officers but suggested improvements were reporting of exports and reuse;

Seventy seven per cent of officers were satisfied, that WEEE collected by

their PCS was not going for illegal export.

38

4.3 Training

The preferred sources of information on WEEE were from Local Authority

Networks and Government sources;

From a list of WEEE related topics the highest ranked was further training in

current and future WEEE legislation. This was chosen as having the most

benefit by 73% of officers.

4.4 Management of WEEE

The majority of WDAs received PCS reports on a monthly basis and 71% of

officers indicated satisfaction on the contents of the report;

WDA officers ranked further audit information on the treatment of WEEE

highest in any reporting improvements that could made by PCSs;

WDA officers ranked „lack of knowledge by householder‟ as having the

highest impact on household WEEE collection figures;

WDA officers rated public communication and increased segregation at DCFs

as the highest achievable measures to increase WEEE collection figures;

WDA officers rated public communication and engagement with reuse

partners as the highest achievable measures to encourage reuse of WEEE.

4.5 WDA Waste Strategies

Overall, WEEE was not prominent in WDA waste strategy policies.

5.0 Conclusions This survey was an inquiry into attitudes and perceptions of WDAs with respect to the existing WEEE collection and treatment in the context of anticipated changes under the WEEE recast .

Overall the WEEE waste stream is part of the larger aspect of waste management controlled and administered by WDAs. Strategically WEEE was not prominent in the waste strategy publications but WDA officers gave WEEE a higher priority in collection and treatment.

The relationship with PCSs indicated that levels of reporting were satisfactory, but WDA officers expressed a requirement for clearly defined accountability from the PCS schemes for audit trails and environmentally correct treatment of WEEE.

The amount of time officers spent on the administration of WEEE was short and therefore it is understandable that any information they require should be concise and comprehensive enough to meet the WDA‟s Duty of Care responsibilities to ensure WEEE is correctly treated.

WDA officers indicated that overall they felt sufficiently knowledgeable in the requirements of the WEEE Directive and the Code of Practice for Designated Collection Facilities.

It would appear that WDA officers were less knowledgeable on the operation of the PCS in relation to the amounts of WEEE collected and whether this was in accordance with PCS‟s obligated requirements. This was also apparent in the identification of the sector that bears the cost of collection and treatment of WEEE.

39

However this is unsurprising, as the WDA is not directly financially involved in the collection and treatment cycle between the Authorised Approved Treatment Facility and the PCS representing producers.

Measures to increase WEEE collection targets and reuse quantities were resource led and focussed on public awareness campaigns for WEEE and increased segregation and DCF operator training.

WDA officers resorted to local authority networks and Government sources for information on WEEE in preference to third party or unofficial sources. These official sources therefore should be the sources of education and further information with regards to government led initiatives on transparency on the WEEE collection and treatment system involving PCSs.

6.0 References BERR (2007) 'WEEE re-use and refurbishment organisations:The role of re-use organisation under the WEEE regulations 2006', Department for Business,Enterprise and Regulatory Reform, The Stationary Office,London., pp 1-2 available at http://www.bis.gov.uk/files/file41127.pdf

BIS (2010) 'Code of Practice for the Collection of Waste Electrical and Electronic Equipment (WEEE) from Designated Collection Facilities', Department for Business Innovation and Skills. available at http://www.bis.gov.uk/assets/biscore/business-sectors/docs/c/10-1007-code-of-practice-collection-weee accessed 01/10/2012

BSI (2011) 'Reuse of used and waste electrical and electronic equipment (UEEE and WEEE). Process management. Specification', PAS 141:2011,132 British Standards Institution, London,

Date, W. (2012) 'BIS official outlines possible WEEE changes', letsrecycle.com. available from http://www.letsrecycle.com/news/latest-news/weee/bis-official-outlines-possible-weee-changes accessed 15/11/2012

DEFRA (2006) 'Environmental Protection; Best Available Treatment Recovery and Recycling Techniques and treatment of Waste Electrical Equipment (WEEE)', Cm 3315, The Stationary Office, London,

DOENI (2011) 'WEEE tonnage collected in Northern Ireland (2010 - 2011) Department of the Environment Northern Ireland', available at http://www.doeni.gov.uk/waste_2011r.pdf accessed 01/10/2012

EU Commission (2003) 'Directive 2002/96/EC of 27th January 2003 on waste electrical and electronic equipment', Official Journal of the European Union, European Parliament, L37, pp 24-29

EU Commission (2012) 'Directive 2012/19/EU of the European Parliament and of the council of 4th July 2012 on waste electrical and electronic equipment (WEEE)', Official Journal of the European Union, European Parliament, L197, pp 38-71

40

European Commission (2012) 'Environment:Recast of the WEEE Directive', European Commision. available at http://ec.europa.eu/environment/waste/weee/index_en.htm accessed 01/11/2012

McDonnell, T. J. & Williams, K. S. (2010) 'Commercial recycling of LCD and its challenges:A UK perspective', 9th International Electronics Recycling Congress, ICM AG, ed., (Switzerland) in Salzburg, Austria, 20 January.

WRAP (2011) 'Realising the Reuse Value of Household WEEE', Waste Resource Action Program, MDD044-001, Banbury Oxon. http://www.wrap.org.uk/sites/files/wrap/WRAP%20WEEE%20HWRC%20summary%20report.pdf accessed 01/11/2012

41

7.0 Appendices

7.1 Appendix 1: Questionnaire

42

43

44

45

46

47

7.2 Appendix 2 Email text Copies of e-mails sent

1 Initial Contact with Identified WDA Dear Sir or Madam

My name is Gus Glover and I work for the Centre for Waste Management at the University of Central Lancashire. We are about to undertake a large project regarding Waste Electronics and their recycling.

We have identified your Authority as a WDA and would therefore request the contact details of your Officer in Charge of Waste disposal. We would also like the contact details of the officer with special responsibility for waste electronics if this is applicable.

We would hope that the study may be of overall benefit to the industry / your authority and that relevant information may be made available following the study.

Yours faithfully Gus Glover BSc (Hons) MSc MCIWM Kirkham Building Preston PR1 2HE 01772 893816 Email: arglover@uclan.ac.uk

2 Pilot e-mail Dear Anthony,

You will recall my previous e-mail (below) regarding our Waste Electrical and Electronic Equipment (WEEE) Survey for Waste Disposal Authorities. We are now in the final throws before general release. Besides the survey design we have had to ensure ethical clearance, complete security and anonymity for all respondents.

As part of this study we are intending to send out an online questionnaire to all WDA‟s. Prior to sending out the survey it is essential that it is first piloted to ensure that the questions are easily understood and relevant.

We are especially interested in the following:

1. How easy is it to complete the survey?

2. How easily understood are the questions?

3. Are there any questions that are not relevant?

4. Are there any questions / options that you think should be included?

Your help in this would be greatly appreciated so we illicit the most comprehensive response and then analyse the data for the benefit of the industry.

Please follow the link provided for the pilot survey. Complete anonymity and security of your response still apply to this pilot stage.

Link www.survey.bris.ac.uk/uclan/wda_weee

This pilot study link will close on Friday 20th July 2012 at 23:50 hrs.

Kind Regards

Gus

48

3 Initial e-mail following receipt of contact information Dear Jane or (named person)

You may recall your authority being contacted recently by a member of staff from the centre for Waste Management at the University of Central Lancashire with respect to a study we are undertaking into WEEE. This research is seeking to determine the attitudes and perceptions of Waste Disposal Authorities with respect of WEEE collection and treatment in relation to the recent proposed recast WEEE legislation.

As part of this study we are currently asking all waste disposal authorities to complete an online questionnaire. The questionnaire should not take you more than 30 minutes to complete and is available by clicking on this link www.survey.bris.ac.uk/uclan/_weee.

Any response to the questionnaire will be totally anonymous. All the information provided will be used responsibly and will be protected against release to unauthorized persons and will not identify you or the WDA. I would reiterate it is only the views of the WDA‟s that are being sought and not those of their contractors or agents.

We would be very grateful if you could find the time to complete this survey and would like to thank you in advance.

If you have any queries regarding the study or the content of this email please contact Dr Karl S Williams (kswilliams@uclan.ac.uk, tel: 01772 893496)

Kind regards

Gus Glover

Gus Glover BSc(Hons) MSc MCIWM Centre for Waste Management University of Central Lancashire Kirkham Building Preston Tel: 01772 893816 Mobile 0771234654

4 Follow-up e-mail (no information received from first request) Hi Roger or (named person)

On the 23/04/2012 we sent an e-mail to your customer services requesting details for the Officer in Charge or with responsibility for WEEE within your authority.

To date we have not received confirmation of the details requested.

My name is Gus Glover and I am employed by the Centre for Waste Management based within the University of Central Lancashire. The Centre has been commissioned to undertake research regarding WEEE management and possible leakage within the system.

We would obviously like to provide the opportunity to all Waste Disposal Authorities to take part in our survey. Although we have a comprehensive database of contacts we would like to confirm that all named persons are still the correct contact. To date I have had a 69% response to my original request for an update and would hope that I can increase this figure.

Could you please provide confirmation that the e-mail address is correct and that you still have responsibility for WEEE within your Authority.

I have added a voting button to this e-mail so you may respond by going to options a clicking yes if you are still the correct contact. However if there are changes an update would be appreciated.

49

Kind Regards Gus

Gus Glover, BSc (Hons) MSc MCIWM

Centre For Waste Management

University of Central Lancashire

A number of other e-mails were sent to named individuals either as a thank you or in answer to a query. As per the following examples

Dear Antony

I really appreciate your response e-mail and understand the difficulty in fully answering some of the questions. If there are any questions that are outside your normal scope of information – do not go to the “ends of the earth” to find the answers. Your response to the questionnaire is anonymous and any answers to questions that are missing or not known will hopefully be corrected in the final statistical analysis of the survey study. Again thank you very much for your response.

Best regards

Gus

Dear Mr Bosley

Thank you for your response. We are putting together the final detail of our study and will contact you again in the near future.

Kind Regards

Gus

Response to a respondent who required information with regard to the survey instigator

Good Morning Doug

Thank you for your reply – certainly the earliest morning reply to date. The initial e-mail was not sent directly to you but to your Council‟s customer services it is therefore likely that it was forwarded to the wrong person or may have gone astray somewhere in the system.

This study has been instigated and funded by REPIC. However University ethics requires us to carry out the study independently and to be impartial, we are also required to censure or reject any question that may be commercially “loaded”. The final document will be made public in its entirety. We also propose to publish the findings in any relevant journal or publication.

We hope our findings will prove both beneficial and of use to the industry.

Best Regards

Gus

Note: Doug was more than happy as Repic are the PCS with responsibility for his WDA.

50

7.3 Appendix 1 BIS Letter to Local Authorities Copy of letter

51

52

53

54

55

56