Circular Economy & Fit for Purpose

My original thoughts were cool we can take materials to a manufacture/drop off point and provide them with not quite raw materials but essentially the same thing, their costs go down, we don’t have to pay high tip fees, everyone’s a winner.

How wrong (or naive) was I…

The concept of a Circular Economy is recycling on steroids, but more about – we are going to run out of land fill sites, essentially storage of our waste as a state/country/world, so what are we going to do with it?

There are definitely benefits to a Circular Economy;

• Use reclaimed/repurposed/recycled materials (less landfill, less embodied energy)
• Supply chain (available materials)
• Design for disassembly, modular construction (MMC)

Cost reduction is definitely NOT one!

After letting this cook for a while I reckon it comes down to three things;

1. The definition of “Waste”, its more complex than you think (definitely for the lawyers)
2. Fees or Waste Levy, a $ amount you need to pay to government for producing waste (hence the definition)
3. Scale (are we talking a few lengths of timber on your roof racks or a yard with the ability to process thousands m³ of timber per year)

So, to the definitions;

• Waste includes –
  • any substance (whether solid, liquid or gaseous) that is discharged, emitted or deposited in the environment in such volume, constituency or manner as to cause an alteration in the environment, or
  • any discarded, rejected, unwanted, surplus or abandoned substance, or
  • any otherwise discarded, rejected, unwanted, surplus or abandoned substance intended for sale or or for recycling, processing, recovery or purification by a separate operation from that which produced the substance, or
  • any processed, recycled, re-used or recovered substance produced wholly or partly from waste that is applied to land, or used as fuel, but only in the circumstances prescribed by the regulations, or
  • any substance prescribed by the regulations to be waste.

A substance is not precluded from being waste merely because it is or may be processed, recycled, re-used or recovered.

Short version, if you no longer want it on your site and intend to remove it, it is most likely waste. If it is waste then you guessed it, fees apply.

If you produced waste, then you pay fees no matter if it being recycled or going to land fill.

In the figure above fees become applicable some where between “Reuse waste” & “Recycle waste”.

So how is it Reuse? – Good question and no I am not joking

In NSW, whether a substance is considered “waste” depends significantly on the state of mind of the original owner (the intent). If you, as the original owner, view a substance as unwanted, surplus, rejected, or abandoned, it is classified as waste under the Protection of the Environment Operations (POEO) Act 1997.

Key Factors;

• Original Owner’s Intent (state of mind)
• Unwanted or Surplus, its waste (even if someone else can use it)
• Recycling Intent, separate operation – its waste (only ceases to be waste once it has been substantially reprocessed)
• Reuse Intent if original owners plan was to reuse, it was reclaimed in an appropriate way (little damage), requiring little to no process for it to be in its original state or purpose , then it is possibly not waste depending on your state of mind
• Environmental Impact if when exposed in the environment it causes pollution
• Lawful Disposal you can only transport waste to a place that is lawfully authorised to receive it i.e. a place with an Environment Protection License (EPL) = Fees
• Stockpiling Temporarily storing unwanted material on your land can trigger “waste storage” licensing requirements = EPL = Fees

Scale, if you want a lot gone its waste, the ability to go and drop off a large amount of material will definitely be considered waste (unwanted/surplus/ requires recycling, processing or purification), if where you take it has a lot of it – its stockpiling (EPL)

Sorry, I can’t stop thinking “government needs to clip the ticket on the way through”.

Hang on, back it up…

I want to repurpose or reuse it;

• At scale – see above, still waste
• Single items or smaller groups of items, keep reading

If your intent was repurpose as a “second hand material” then it depends on the items and your ultimate goal for them.

In a circular economy, these are two distinct categories:

• Intention was Reuse
  • If your goal was to prolong the life of an item/material
  • You demolish, reclaim, separate in a suitable manner, very little damage
  • Item/material requires no treatment and/or very little processing to return it ready for its original purpose/use
  • Yes, it is considered second hand, subject to factors above

• Intention was Disposal
  • It is waste
  • If there is scale, unwanted, surplus, requires recycling, processing, its waste

So, if your goal is to resell, repurpose, reuse then make sure;

1. Item is identified prior to demolition, stripping, separation
2. You have given the item a value (monetary, sentimental, historical)
3. Demonstrate you still want it, stored correctly etc.
4. Don’t make a big thing of cutting it or pulling the nails out (processing)
5. It can be reused with a similar purpose as it was in its previous use

With the above it can not be considered “Waste” I am sure there will be a lawyer out there with a different opinion.

If you choose to sell/move it to another location/give to a new owner it is a “2nd hand material” not waste.

All depending on your “state of mind” of course!

What happens next, (risk management)!

• Council, Building Surveyor, Certifier, Engineer should ask is it “Fit for Purpose”?, is there a warranty? (regulatory/liability)
• Can I get it in enough quantity? (buildability)
• Owner/Community perception of quality? (reputation)
• Will if perform as expected/understrength? (safety)
• Resale/Valuation of building with repurposed material? (financial)
• Poorly inspected/certified, moisture/mould/contaminants (health)
• Insurance (all of the above)