Case Study Author: Martin Fryer Position: Environmental Manager Organisation: Geest Plc Keywords: Waste Packaging Producer Responsibility and Packaging Waste - an Industry Perspective Geest Plc is a main supplier of branded fresh and prepared food products to all the major supermarket chains in the UK. This article is a case study of the impact on the company of the Producer Responsibility Obligations (Packaging Waste) Regulations 1997. It assesses the use of the Packaging Recovery Note (PRN), the economic instrument associated with the Regulations, and the impact of the UK Government's decision to increase recovery and recycling targets in 2001 above those first legislated for. Geest history Geest has its origins in the horticultural and fresh produce sector. The Van Geest brothers began growing bulbs in Spalding, Lincolnshire and developed from this into a fresh produce business. In 1953 Geest began trading with the Windward Islands and imported bananas, an activity for which the company is most commonly known. In the early 1970's the company diversified into prepared foods, opening the first dressed-salads factory in Spalding, Lincolnshire. Throughout the seventies and eighties the company grew through organic growth and acquisitions providing branded products to the major retailers. In 1996 the banana side of the business was sold to Fyffes. The approach to information During the formative stages of the packaging waste regulations in 1997 Geest submitted data to the Environment Agency based on 1996 usage. This was to assist the UK Government in establishing packaging use by UK Plc. Gathering the information and presenting it in an auditable form proved to be a time consuming and difficult task. To avoid duplication of effort and the creation of 24 different systems for calculating each business unit's obligations, the decision was made to produce the data centrally making one application to the compliance scheme. The method employed concentrated on volumetric data taken from stock adjusted goods received (SAGR) records. The SAGR records contain the quantities of all purchases made by business units from packaging, raw materials and sundries. Details include the opening stock, closing stock and usage figures. Each packaging item used has a part code or 'P' code and each raw material an 'M' code. This approach seemed to provide an adequate level of accuracy. Information on the weights and sources of packaging and materials was obtained from suppliers using proforma datasheets. The source of packaging and raw materials was also crucial to an accurate calculation. IEMA St Nicolas House 70 Newport Lincoln LN1 3DP UK Tel: +44 (0) 1522 540059 http://www.iema.net/ Case Study Data collection The majority of Geest's obligations come from its packer filler operations but the company also imports packaging (with a rolled-up obligation) and raw materials (picking up 100% of the obligations on tertiary packaging). Geest also exports products for which the weight of packaging has to be removed from the obligation. With 3,000 food recipes, over 6,000 packaging items and several hundred packaging and raw material suppliers the task was not to be underestimated. In the first year spreadsheets were created using Microsoft excel to calculate individual business unit obligations. Each individual packaging item was listed and its weight taken from supplier data. Usage figures for the packaging came from the SAGR records. The only drawback with this approach was that the records were not a secure data source - they could be altered by several people within the organisation and their accuracy could be questioned. This could lead to an over or under estimation of the company's obligation. However, for the legislative requirement of “a reasonable estimate” this method was deemed adequate. To test the approach, we commissioned an independent audit by Environmental Resource Management who spent several days following the audit trail and assessing the accuracy of the data collection system. They found it difficult to reach meaningful conclusions because industry response to the legislation was in its infancy and there were no benchmarks or standards for comparison. However the final report was broadly favourable. Some developments The problems with the SAGR approach were that the number-crunching exercise was an enormous task and it could only be done at the year-end. This made it difficult due to the end of February deadline set by Valpak, the compliance scheme. In terms of personnel, Geest employed one full time Legislative Compliance Controller and at least two, but sometimes up to four, part time staff to cross check data and chase business units or suppliers for information. Internal cross checking of data was done using the Bill of Materials (BOMS). The BOMS is a recipe for every product manufactured across the company. It shows sales, use of raw materials, packaging and costs for each product. The sales and usage data provided a useful cross check to determine the accuracy of the calculations for the whole company. In 1999 the system was partly automated by the creation of a database using Microsoft Access, this gathered information from the variety of sources but could only be used for the prepared-foods side of the business. The system worked well but the size of the database and the complex calculations were, at times, too much for the software to handle. In 1999, we were audited by Valpak in August and by the Environment Agency in August and December. Both audits confirmed the data met the required levels of accuracy. They highlighted the company's enormous range of packaging types, raw material sources, products and customers and the complexity of the calculations that had to be undertaken. The Agency and Valpak had difficulty in covering all areas of the business in a one-day audit. The huge volume of paperwork generated by the Access and Excel spreadsheet systems hindered the process. The Agency made some recommendations for improved data accuracy, particularly in relation to exports. It became clear that a software solution was required to ease the obligation calculations, reduce the manhours spent on the task and improve the accuracy of the calculations. Computer software Towards the end of 1999 Geest purchased an off-the-shelf software solution to help improve data accuracy and its ability to respond to customer requests for packaging data. The new software 'Packtrack' required hardware in the form of an SQL7 server. The combined package cost in the region of £16,000. IEMA St Nicolas House 70 Newport Lincoln LN1 3DP UK Tel: +44 (0) 1522 540059 http://www.iema.net/ Case Study This proved to be a sound investment. The number of personnel required to calculate the obligation was reduced to two part-time, the environmental manager and an environmental assistant. Also, the financial burden of the regulations had not been as great as expected, membership of Valpak was proving cost effective and obligation costs had actually gone down year on year. 'Packtrak' is able to take part code and product recipe information from the BOMS off the company's 'impcon system. For those business units not on 'impcon', spreadsheets are still being used. However, 'Packtrak' can be updated with tables so the obligated tonnage from these business units can be added to the company's total. Existing packaging weight data and any new packaging item weights can also be loaded into the 'Packtrak' database. By loading in sales files from business units their obligations are calculated automatically. The software supplier, Foresite Systems updates the software to take account of any changes to the regulations and percentages for recovery and recycling obligations. This allows the user to concentrate on the accuracy of the data being put into the system rather than worrying about the accuracy of the calculations. For Geest, the installation of 'Packtrak' has also meant data can, for the first time, be loaded throughout the year as opposed to an end-of-year exercise. With uncertainty over the future cost of the regulations, due to the PRN market and possible price fluctuations, the ability to predict obligated tonnages and potential costs is invaluable. In addition 'Packtrak' has helped to improve our response to customer requests for packaging information. Auditing Over the past four years Geest has generated a large database of packaging item weights and new packaging items are continually being added as new products are designed and launched. During 1998 and 1999 over 2,000 packaging item weights were added to our database. With only two full-time staff in the environmental section an audit of all packaging suppliers was an unrealistic aim. A decision was taken to select a sample for audit purposes. Audits have been undertaken on a small number of the 3,000 recipes available, tracing the packaging chain from product to supplier. The audits were designed to check the accuracy of weight data, examine heavy metal contamination and investigate the use of laminates and their recyclability. One encouraging finding was that Geest's suppliers were also putting in place systems to improve the accuracy of their data. Waste management and PRNs Geest also generates large quantities of packaging in back-door waste, particularly from those sites that import raw materials or packaging items. It was hoped that the good quality card found on imported fresh produce could be used to offset some of our obligation and in 1998/99 several waste management companies were approached to provide equipment, collection facilities and hopefully PRNs. The response was disappointing, the attitude from most if not all waste management companies was that recovery and recycling services could be provided but at a cost and if Geest wanted PRNs then there would be an additional cost. We decided to set up an integrated waste management system at our main site at Spalding. Cardboard Connection Ltd. provided the equipment and an income is produced from this waste - bulked-up steel also provides an income. These initiatives have reduced considerably the amount of waste going to landfill. The question remains as to whether PRNs are useful as an economic instrument, our efforts have produced no benefits to date? Geest is striving for continual improvement in its environmental performance. The recovery and recycling of waste is one contribution to the aim. We had hoped to contribute more to the ethos of the packaging waste regulations by diverting packaging waste away from landfill. But the current PRN system has provided no incentive for us to do that. The future of the PRN market is uncertain and the present reliance on export markets for generating PRNs at the cost of some UK IEMA St Nicolas House 70 Newport Lincoln LN1 3DP UK Tel: +44 (0) 1522 540059 http://www.iema.net/ Case Study reprocessing capacity surely goes against the whole philosophy of the regulations and the use of economic instruments? In 2001, the recovery target is to be raised from 52% to 56%, this is happening because the UK is in danger of failing to meet the European target. This will penalise companies like Geest who have taken the regulations and their responsibilities as producers of packaging waste seriously. For Geest the potential financial impact of the new recovery targets is in excess of £200,000. An interesting parallel in the use of economic instruments can be drawn with the recovery and recycling of household waste. In the UK, local government was set a target in 1990 of recycling 25% of household waste by the year 2000 and an economic instrument “the recycling credit” was introduced to provide money for investment in recovery and recycling systems. The target was not reached, in fact the UK failed to reach double figures and the target has recently been reviewed. Time should be taken to ascertain whether the use of economic instruments is effective in waste recovery and recycling, particularly when so much rests on the need for an expanding end market for recycled materials and products which does not currently exist in the UK. Note This article was published in 'the environmentalist' in January 2001 IEMA St Nicolas House 70 Newport Lincoln LN1 3DP UK Tel: +44 (0) 1522 540059 http://www.iema.net/