FOLLOWING serious consternation among the packaging industry about the significantly reduced timeframes given to submit an Industry Waste Management Plan (IWMP), the Department of Environment Affairs (DEA) has formally withdrawn the 12 August Section 28 notice calling for this. A new ‘intention to call for plans’ notice was published on 12 September which gave the industry 30 days to submit written representations or objections to its contents.
The latest notice requires industry members to register with the DEA before 12 September 2017. Within 12 months of registering, industry members need to prepare and submit their IWMP to the Minister for approval.
The notice has extended the pool of entities required to submit and prepare or subscribe to an IWMP from ‘producers’ under the draft notice to all producers, recyclers, collectors, processors, reclaimers, recycling advocacy associations or entrepreneurs “in relation to a waste stream”.
Onerous contents for an IWMP are imposed in the notice. This includes how affected Industries will prioritise reduction, re-use and recycling and then recovery of waste and implement measures to give effect to best environmental management practice.
Incentives and financial contribution that will be applied to encourage end users to practice good waste management and measures to increase national awareness are also required. Social responsibility issues and methods to include the formal sector in the plan would need to be addressed.
The full process to submit an IWMP includes necessary research, drafting the plan, circulating it to stakeholders for comment, revising it, publishing it as well as opening it up for objections and representations for 30 days, responding to the objections and finalizing representations before submitting it to the Minister.
Compounding the pressure to comply is the fact that a failure by any affected entities to comply with the new shortened time periods for registration and the preparation and submission or subscription to an IWMP is an offence which may lead to a fine and/or imprisonment of up to 15 years.
“A well thought-out and carefully constructed plan is vital for the packaging industry to ensure that the aim of cleaning up the environment, creating new markets for recycled products and creating jobs is achieved, while at the same time building on the significant progress that has been made thus far,” said Plastics/SA executive director, Anton Hanekom.
He said that Plastics/SA intended to work closely with Packaging SA in the preparation and submission of an IWMP.