News, Opinion

Solving commercial challenges when tracking hazardous waste

Hazardous waste – it’s a health risk, a destructive contaminant in recycling, and an expensive material to process. In Victoria, it’s also subject to a huge landfill levy of $250 per tonne. Due to its cost and complexity, there has been big incentives for those unwilling to pay the levy to illegally dump material, resulting in stockpiles and hazardous dump sites.

While the most high-profile, illegal dump site was the Bradbury site at Campbellfield, which burnt to the ground in April 2019, there have been many smaller examples. The Bradbury’s accident resulted in a multi-million-dollar taxpayer-funded cleanup. Beyond the immediate costs, it also undermined the legitimate industry, which is working hard to process the material safely and to a high environmental standard.

To solve this issue, Victoria is the first Australian jurisdiction to implement digital tracking for hazardous waste. Broadly, this is a welcome development. Using an application called ‘Waste Tracker’ and an online portal, the new system tracks hazardous waste from source to processing facility in real-time.

Victoria has stepped into the digital arena to implement a necessary system. The state has offered to be a proving ground for the rest of Australia’s jurisdictions to eventually follow, all of which are still using paper-based systems.

However, like any new system, Waste Tracker has been subject to growing pains, and industry is now feeling this. The state government and industry have been working hard to remove bugs, with the system improving week-by-week since it went live and became mandatory on 1 July.

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The process of iterative improvement has revealed a critical challenge for digital waste tracking. This challenge is protecting important commercial-in-confidence information while maintaining transparency. Fundamentally, Waste Tracker is designed to create transparency right across the supply chain – from the producer, the transporter through to the final destination for the material – with all this information visible to all stakeholders in the system.

The system was designed this way to ensure that processors have visibility of where the material is sourced from in order to resolve contamination challenges, and to ensure tracking of liability if something goes wrong. Each party in the supply chain has a responsibility; the producer must accurately characterise their waste; the transporter must move it safely and to a lawful place; and the processor must ensure safe disposal or recovery of the material.

This system was designed to be self-policing by linking each part of the supply chain together, in a similar manner to chain of responsibility for heavy vehicles. Unfortunately, this regulatory design creates an unintended negative consequence.

This system potentially leaks commercial information from waste collection contractors to larger companies that process waste, who are their competitors.

In other words, when waste producers put their details into the tracking system, these details are passed onto the waste processor, even if they are not their customer. This prevents waste transport companies from keeping their customer lists strictly confidential.

Fundamentally, there is a contradiction between accountability/transparency across the supply chain and maintaining critical commercial confidence, which is important to ensure diversity and competition in the marketplace. In Victoria, the EPA, DELWP must find a solution to this challenge, or risk their system being knocked down under competition laws.

After members brought this issue to our attention, the VWMA has been working with the EPA and the DELWP to develop a solution. While the final fix is yet to be determined, fundamental information needs to be carefully funneled through the system so that only the EPA has total visibility, and that contractors can work to collect waste without the risk of losing their customer lists.

In regard to other stakeholders, the VWMA is arguing for information sharing that excludes all customer details. Information should only be shared when it is necessary for environmental compliance across the entire supply chain.

Once a solution is found, Victoria’s model of digital waste tracking can be an example to other jurisdictions, creating a nationally harmonious hazardous waste tracking system to protect workers, the community and the environment.