National Waste & Recycling Association Comments on California Recycling, Safety Regulations

The National Waste & Recycling Association (NW&RA) recently provided comments to two California regulatory bodies on two separate rule proposals, respectively involving the state’s 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’s recent recommendations for further action to meet the state’s recycling goal of 75 percent by the year 2020, NW&RA expressed concern with the agency’s lack of specificity and foresight of how to reach the benchmark.

“While Association members support recycling and have invested heavily in building California’s 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,” wrote Chaz Miller, NW&RA’s director of policy/advocacy, in the association’s 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.

“These questions are crucial to the success of meeting an ambitious source reduction, recycling and composting target, yet they are unaddressed,” Miller said.

NW&RA also rejected CalRecycle’s recommendations for mandatory initiatives issuing “extended producer responsibility” for package producers, as well as a possible ban on recyclables being sent to landfills.

“Extended producer responsibility as practiced [elsewhere] is, at best, a flawed funding mechanism,” he said. “Producers only pay for what they consider to be the ‘reasonable’ costs of recycling packages. They will not pay a local government its full costs if they do not consider those costs to be reasonable.”

Regarding safety, NW&RA commented to Cal/OSHA, concerned that its recent proposal to reduce the allowable speed for “right side drive” waste collection vehicles will instead undercut recent national momentum in improving worker safety in the waste industry.

“No 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,” said David Biderman, NW&RA’s vice president of government affairs. “Cal/OSHA’s 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.” 

To view the full comments NW&RA provided to CalRecycle, please click here. To view the comments provided to Cal/OSHA, please click here.