The National Waste & Recycling Association (NW&RA) recently provided comments to two California regulatory bodies on two separate rule proposals, respectively involving the state鈥檚 recycling goals and waste collection vehicle safety. NW&RA submitted its comments to the California Department of Resources Recycling and Recovery (CalRecycle) and the California Occupational Safety and Health Standards Board (Cal/OSHA). In response to CalRecycle鈥檚 recent recommendations for further action to meet the state鈥檚 recycling goal of 75 percent by the year 2020, NW&RA expressed concern with the agency鈥檚 lack of specificity and foresight of how to reach the benchmark. 鈥淲hile Association members support recycling and have invested heavily in building California鈥檚 existing recycling infrastructure, CalRecycle fails to explain how its recommendations will aid California in achieving its legislatively mandated goal of 75-percent source reduction, recycling and composting,鈥� wrote Chaz Miller, NW&RA鈥檚 director of policy/advocacy, in the association鈥檚 comments.
Specifically, Miller wrote that CalRecycle failed to include specific discard tonnages for its list of seven priority packaging products and failed to analyze where those products are generated, how they will be recovered or what a realistic recovery rate would be for those products. 鈥淭hese questions are crucial to the success of meeting an ambitious source reduction, recycling and composting target, yet they are unaddressed,鈥� Miller said.
NW&RA also rejected CalRecycle鈥檚 recommendations for mandatory initiatives issuing 鈥渆xtended producer responsibility鈥� for package producers, as well as a possible ban on recyclables being sent to landfills. 鈥淓xtended producer responsibility as practiced [elsewhere] is, at best, a flawed funding mechanism,鈥� he said. 鈥淧roducers only pay for what they consider to be the 鈥榬easonable鈥� costs of recycling packages. They will not pay a local government its full costs if they do not consider those costs to be reasonable.鈥�
Regarding safety, NW&RA commented to Cal/OSHA, concerned that its recent proposal to reduce the allowable speed for 鈥渞ight side drive鈥� waste collection vehicles will instead undercut recent national momentum in improving worker safety in the waste industry. 鈥淣o federal, state or local government safety fact sheet concerning the industry has ever identified falling out of a right side drive vehicle as a priority concern,鈥� said David Biderman, NW&RA鈥檚 vice president of government affairs. 鈥淐al/OSHA鈥檚 proposed revisions are contrary to national best practices for such vehicles and drivers as set forth by the American National Standards Institute, and undercut the ANSI Z245 safety standards.鈥�
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