UBC Theses and Dissertations

UBC Theses Logo

UBC Theses and Dissertations

Product stewardship initiatives : the case of post consumer paint in BC Mugabe, Barbara Caroline 1998

Your browser doesn't seem to have a PDF viewer, please download the PDF to view this item.

Item Metadata

Download

Media
831-ubc_1998-0556.pdf [ 3.63MB ]
Metadata
JSON: 831-1.0088654.json
JSON-LD: 831-1.0088654-ld.json
RDF/XML (Pretty): 831-1.0088654-rdf.xml
RDF/JSON: 831-1.0088654-rdf.json
Turtle: 831-1.0088654-turtle.txt
N-Triples: 831-1.0088654-rdf-ntriples.txt
Original Record: 831-1.0088654-source.json
Full Text
831-1.0088654-fulltext.txt
Citation
831-1.0088654.ris

Full Text

Product Stewardship Initiatives The Case of Post Consumer Paint in BC by BARBARA CAROLINE M U G A B E B.E.S., York University, 1996  A THESIS SUBMITTED IN PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF MASTER OF ARTS, PLANNING in THE FACULTY OF GRADUATE STUDIES ( School of Community and Regional Planning)  We accept this thesis as conforming to the required standard  T H E U N I V E R S I T Y OF. B R I T I S H C O L U M B I A August 1998 © Barbara Caroline Mugabe  In  presenting  degree  this  thesis  at the University  in  partial  fulfilment  of British  Columbia,  freely available for reference copying  of  department publication  this or  thesis by  of this  and study.  f o r scholarly  his thesis  or  her  of  I agree  I further  purposes  gain  that  agree  that  shall  It  is  Department of £ck*Jo/Co«»onif>y The University of British Vancouver, Canada  Date  DE-6 (2/88)  i3> Oc-lolef  Columbia  /9-7S  * Py^t  permission  not be allowed  Plowru^  advanced  shall  make it  for extensive  by the head  understood  permission.  for an  the Library  may be granted  representatives.  for financial  the requirements  that without  of my  copying  or  my written  Abstract The outcomes o f the paint stewardship program in British Columbia are examined to assess whether the objectives o f the program and the principles o f product stewardship are being achieved. The objectives are to: 1) compel the paint industry and consumers to take responsibility for waste paint; 2) minimize the volume o f paint landfilled; 3) raise consumer awareness about the impacts on the environment o f excessive waste generation, and the need to opt for environmentally friendly practices.' The methods o f research used include secondary literature, a survey and interviews. Due to the unavailability o f some crucial data, I could not carry out a proper program assessment. The following are some insights into the program: 1) waste paint collected increased from 1,300,000 equivalent litre containers i n 1995 to nearly 3,000,000 i n 1997. However, without knowing the volume o f paint sold annually, these figures reveal little about the effectiveness o f the program; 2) O f the residual paint collected i n 1997, 5 1 % was recycled into products other than paint, 30 % involved energy recovery, 11% was landfilled, while 8% was reused. I discussed the need to increase the volume o f paint reused as doing so prevents the problem o f waste paint from arising in the first instance. There are both benefits and flaws associated with the process o f recycling. Compared to reuse, recycling does relatively little to solve the problem o f waste reduction; 3) In the absence o f crucial data, the objective o f compelling the paint industry and consumers to take responsibility for waste paint is so far merely theoratical. The paint program is consumer funded and industry operated.  1  (source: http://www.qp.gov.bc.ca/stat_reg/regs/elp/200_94.htm).  ii  In practice, a 50c ecofee/litre paint has not served as an incentive to encourage consumers to bring residuals to a depot. N o r has it resulted in meaningful changes in consumption habits. A 50c ecofee also means that paint sales w i l l not likely be affected. It appears the industry is charging this low fee despite the fact that it does not lead to the achievements of the objectives outlined for the program. While a paint program is now in place for the processing o f residual paint, the program cannot be assessed based on its objectives. To enable meaningful program evaluation, the primary recommendation is for the authorities monitoring the program to collect the relevant data over time in order improve program effectiveness.  in  T A B L E OF CONTENTS ABSTRACT  i  TABLE OF CONTENTS  Hi  LIST OF FIGURES  v  ACKNOWLEDGMENTS  vi  CHAPTER 1 1.1 1.2 1.3  INTRODUCTION  Focus and Purpose of Thesis Product Stewardship Concept Organization of Thesis  CHAPTER 11 BACKGROUND  1 1 3  TO THE PROBLEM  2.1 The Economy-Environment Link  4  2.2 The Problem with'Waste'in General  7  CHAPTER 111 THE CASE STUDY 3.1 Issues Associated with'Waste'Paint  8  3.2 Fire and Safety Issues 3.3 Environmental Issues 3.4 Economic Issues 3.5 A New Policy for Managing Waste Paint 3.6 Duties of the Brand-Owner 3.7 Reporting to the Director 3.8 Provision of Information to Consumers 3.9 Liability 3.10 Paint Industries Comply with Regulation 3.11 The Ecofee 3.12 Objectives of the Paint Stewardship Program CHAPTER 4 4.1 4.2 4.3 4.4 4.5 4.6  RESEARCH  9 9 9 11 11 12 12 12 12 13 14  METHODS  The'Paint Program Stewardship Theory'of the Paint Specific Research Objectives and Questions Limitations of Research Methods Criteria for Assessing General Performance Criteria for Assessing Environmental Protection Criteria for Assessing Ecofee Effectiveness  CHAPTER 5 RESEARCH FINDINGS 5.0 Difficulties Encountered During Data Collection 5.1 Residual Paint Collection Facilities 5.2 How Much Paint is Collected Monthly? 5.3 How Much Paint is being Collected Annually? 5.4 How Much Residual Pant Is Being Processed?  IV  15 16 18 19 20 21  22 25 26 27 31  5.5 Why there is no Widespread Reuse of Paint? 5.6 The Problem with Recycling and Recycled Paint 5.7 Recognizing the Limits to Recycling 5.8 Treatment/Containment 5.9 Is the Polluter Pays Principle Working? 5.10 Employment Creation 5.11 Availability of Free Paint 5.12 Influence of the Program on Other Groups CHAPTER 6  6.1 6.2 6.3 6.4 6.5  ANALYSIS OF THE RESEARCH FINDINGS & THE PAINT PROGRAM  Is There A Need for This Specific Program? Is Paint A Waste? The Critical Role of the Consumer The Paint Industry & The Paint Program Implications of Research Findings on Environmental Protection  CHAPTER  32 33 35 35 36 39 39 39  7 Recommendations and Conclusions  41 42 45 46 46  51  Works Cited  56  Appendix 1 Hierarchy of Options Within Waste Management  60  Appendix 2  61  Post Consumer Paint Stewardship Regulation  Appendix 3 Paint Ecofee  69  Appendix 4 Consumer Questionnaire  70  v  LIST OF FIGURES F i g 1 Paint Collection Facilities in B C F i g 2 Monthly Paint Collection 1995-199 F i g 3 Annual Paint Collection 1995-1997 F i g 4 Post Consumer Paint Processing 1997  vi  25 26 27 31  Acknowledgments Several people assisted and enabled me to prepare this thesis. I wish to acknowledge their support and guidance. M y thesis supervisor, B i l l Rees clarified several points and offered the much needed insightful comments and guidance which I found useful particularly useful during the development o f the thesis. Thanks B i l l . M y second reader, Raymond Young pointed out some grammatical errors and issues or areas that needed to be refined to enhance the overall clarity o f the thesis. Thanks Raymond. I carried out interviews with key informants most o f whom asked to remain anonymous. They provided me with data and directed me to sources of information that are used in this thesis. Thank you for assisting me. The P E O scholarship that I received could not have come at a better time. Thanks to my sponsors for their generosity, moral and financial support. I would like to express my gratitude to my network o f friends who cheered me up and boosted my morale when it was getting low. Finally, I am truly grateful to my mum. Her loving support has helped me come this far.  Ishe anesu amai. Anesu!  Vll  INTRODUCTION Focus and Purpose of Thesis This thesis focuses on the product stewardship approach adopted by the province o f British Columbia as a practical solution to the problems o f 'waste' paint.  The overall  purpose o f the thesis is to contribute to advancing product stewardship as a feasible strategy for waste management. I examine the outcome(s) o f the consumer-funded and industry-operated Paint Stewardship Program established in the province o f British Columbia in 1994 to: 1) minimize the volume o f post consumer paint disposed o f in landfills; 2) force manufacturers and consumers of paint to be responsible for 'waste' paint; and 3) raise awareness about the effects o f our consumption habits on the environment and appeal to consumers to opt for environmentally sound practices (http://www.qp.gov.bc.ca/stat_reg/regs/elp/r200_94.htm). I explore the outcomes o f the paint program with a view to assessing whether the principles o f product stewardship have been attained by the paint program.  More  specifically, I probe into the outcomes in order to determine i f the ecofee is resulting i n a decrease in the volume o f 'waste' paint generated. A s well, I am keen to examine how the paint industry has changed or been affected, i f at all, by the paint stewardship legislation and the subsequent paint program.  Product Stewardship Concept In its broadest meaning, the concept o f product stewardship suggests the manufacturers o f products that become waste should bear responsibility for those products, throughout the life -cycle from the selection o f raw materials all the way through the waste management  1  hierarchy and the final disposal of the products once they become waste  ( The  Newsletter o f the Recycling Council of British Columbia, 1993:11) {refer to Appendix 1 for a description of the waste management hierarchy). The product stewardship concept extends the widely accepted 'polluter pays principle' (PPP)  by accounting for the pollution caused by a product after it is purchased, in  addition to the pollution caused during its production. In Our Common Future.. 1997. W o r l d Commission on Environment and Development). (PPP) is described as essentially an economic efficiency measure and when applied in the context o f product stewardship, it theoretically has an immediate effect on waste management:  When the cost o f  managing product waste is internalized as one o f the costs of doing business i n the case o f industries and o f consuming products that become waste in the case o f consumers, an incentive is created for waste reduction. The Ministry o f Environment anticipates that the application o f the product stewardship concept to hazardous waste management w i l l encourage industries to strive to phase out hazardous products requiring special disposal for which the industry w i l l be held responsible. A s well, the ecofee paid by consumers is expected to remind them o f the costs of safe disposal and the need to minimize environmental impacts o f products.  The  province of British Columbia has incorporated both the product stewardship concept and the polluter pays principle as guidelines for its waste management  policies. The  responsibility for paint waste now borne by the paint industry and paint consumers is part  Substituting toxics with environmentally benign raw materials reduces the overall level of toxicity in the end product. The complexity of processing such a product once it becomes post consumer waste is relatively simpler and the costs involved will likely be lower.  2  of the price o f producing and consuming a can of paint.  British Columbia's paint  stewardship regulation is the first North American example o f 'Industry Stewardship' legislation. It is an example of a solid stewardship program with all o f the costs shifted on to the 'steward'.  Organization of the Thesis The thesis comprises five chapters.  The first section is a brief description o f the focus  and purpose of the thesis. A detailed problem statement is laid out in Chapter 1 drawing attention to how excessive economic activities impact on the natural system. Emphasis gradually shifts to the problem of 'waste or garbage' and how to manage the waste in such a way as to minimize environmental harm. A case study o f the Paint Stewardship Program is presented in Chapter 2 in which the program and the events leading to the establishment o f the program are described. The methods o f study used are described in Chapter 3 .  Chapter 4 describes the findings of the research.  Chapter 5 focuses on an  analysis o f the findings and as well, several issues are discussed concerning the program and the concept of stewardship. Recommendations and final thoughts about product stewardship initiatives w i l l wrap up the thesis.  BACKGROUND TO THE PROBLEM The Economy - Environment Link The connection between the economy and the environment is currently a subject o f much discussion. Ecological economists such as Perrings, (1997)., Rees, (1989)., Costanza, Perrings and Cleveland, (1997)., and Daly, (1977)., have written extensively about the ways in which the economy and the environment connect. Economic activity depends to a great extent on raw materials and energy from the natural system which also acts as a sink for wastes emanating from economic activity.  The economy can be thought o f as  comprising two physical populations- people and the products they create- existing as elements o f a larger natural system. In explaining the economy-environment link, Daly (1977) refers to the Steady State Economy which is based on the premise that the human economy is an 'open sub-system of the earth ecosystem, which is finite, non growing and materially closed'. Daly describes steady state economy as a non -growth economy in biophysical equilibrium where (a) stocks are maintained at a level sufficient for abundant life for the present generation and ecologically sustainable for an indefinite future; (b) service is maximized given constant stock; (c) throughput is minimized (Daly, 1977:13; Costanza, Segura and Martinez., 1966:49; and O E C D , 1997:60). The natural system is, in essence, a source of inputs of matter-energy for the economy and a sink for its outputs. The total of resource consumption (throughput), by which the economic subsystem feeds off the containing ecosystem, is limited - because the ecosystem that both supplies the throughput and absorbs its waste products is itself limited (Costanza, Segura and Martinez, 1964:49 and Daly, 1977:13).  4  In the last half o f this century in particular, excessive consumption and waste generation activities within the economy are exerting increasing pressure on the natural system and compromising its capabilities. The gap between the economy and the natural system is emerging because the values and mechanisms o f neo-classic economics do not take into account the limitations o f the natural system.  The depletion o f the fisheries in  Newfoundland; the ozone holes in the Antarctic and Arctic; and the 'garbage crises' faced by cities throughout the world illustrate the imbalance that conventional economics has created between consumption and waste generation processes and the natural processes o f regeneration and waste assimilation. In accounting for environmental problems stemming from economic activities, I think it is important to examine how industry's attitude towards the environment does or does not foster a harmonious relationship between the economy and the natural system.  O'  Callaghan (1996:18) studied industry's perception of what the relationship is or ought to be between the economy and the environment. His results showed that according to the current system o f doing business, "The faster the throughput the more money flows, the faster the rate o f consumption and the greater the level o f consumer satisfaction'.  O'  Callaghan concluded that ' most industries including the paint industry, perceive environmentally sound approaches to doing business e.g. conserving resources through recycling and pollution prevention, as obstacles in the system. Such obstacles are said to 'dry up money, and profits, as well as consumer satisfaction" ( O ' Callaghan, 1996:18). This attitude imbedded in the current economic system is creating environmental problems such as massive volumes of waste that cause various kinds o f pollution.  5  Fortunately, not all industries have the mind-set described by O'Callaghan. There are some which are interested in bridging the gap emerging between the economy and the natural system. A s a matter o f fact, industries such as Union Carbide have discovered that certain mechanisms to curb environmental degradation do not necessarily translate to profit loss or consumer dissatisfaction (Collier, 1995). Such industries are presently few in number and for this reason, the Ministry of Environment in B C is being compelled to encourage a greater number of industries to 'go green'. A  high rate o f recycling in the paint industry for example, could result not only in the  maintenance o f the current profit level, but the industry would also acquire a good environmental record by reducing pollution. Perrings (1997:98) further explains that the existence o f external effects in an economyenvironment system is a function o f both extractions and insertions into the processes o f the environment. The first implies the depletion of environmental resources, the second involves the pollution of environmental processes. Residuals generated in the economy may be applied either to the processes of the economy as investment, or the environment as waste. Before moving on to product stewardship in which residuals are directed back into the economy as investment, I w i l l discuss one of the major externalities o f the market economy- post consumer 'waste' in general and paint 'waste' in particular and the problems associated with it British Columbia.  6  The Problem o f Wastes' in General Managing post consumer waste is a growing problem with which cities throughout the world are grappling.  Serious concerns about environmental degradation and anxiety  about diminishing landfill capacity are forcing local governments to search for solutions to the problem o f wastes.  The overall quantity of postconsumer waste generated in  British Columbia is increasing due to factors such as: growth in total population; each person appears to be generating more waste on average; the total volume o f waste generated is increasing because o f trends in the production of single use, disposal items (Lower Mainland Refuse Project. 1984:7). A s the volume and rate o f consumption of paint and other goods increases, the total volume o f 'waste' dumped onto the environment increases while the ability o f the natural system to absorb all the waste is diminishing. Concern over rates o f consumption and 'waste' generation is increasing and this fear rests on two notions: •  more economic output requires more resource inputs and so the earth's 'sources' o f natural resources inevitably w i l l be depleted by continued growth o f production and consumption;  •  more output means more waste emissions and so the earth's 'sink' w i l l become overburdened by continued economic growth (Golding and Winters, 1995:19).  Costanza, Segura and Martinez (1996:54) argue that there is both a benefit and a cost to increasing the scale of the subsystem (economy). The benefit is economic service gained ( e.g. increasing the aesthetics of buildings by painting as well as protecting the buildings from the elements). The cost is ecosystem services sacrificed ( e.g. raw materials  7  extracted and thus no longer available to perform environmental and biophysical functions impaired by pollution). Concern over unchecked and inefficient use o f virgin materials i n the manufacture o f goods is being expressed not only by ecological economists and environmentalists. Organizations such as the Organization for Economic Community Development have also observed that manufacturers have been deliberately reducing the time period for which a product remains operational ( O E C D . 1982:33).  Issues Associated with 'Waste' Paint Hazardous household products are those that contain components or substances which either individually or i n combination are toxic, corrosive, or flammable, such as paints and solvents.  Hazardous ingredients have been widely used within the paint industry,  perpetuating a legacy o f environmental damage for generations to come. According to the Waste Reduction Commission's Report on a Provincial Strategy to Reduce and Manage Household Hazardous Waste Products (1994:5). paints make up about 22 to 40 percent o f household hazardous waste. Keeping paints and solvents away from the municipal waste stream means the largest item o f household hazardous material would be receiving some form of treatment prior to landfilling. Problems o f 'waste' paint are twofold; one is that o f how to manage waste paint i n a way that does not cause environmental problems; second, who should pay for managing residual paint.  Before answers can be furnished to either o f these questions, it is  important to give details about the issues and concerns associated with 'waste' paint.  8  Fire & Safety Issues Paints and solvents present fire, health and safety hazards when improperly handled or stored. O i l paints i n particular contain a variety o f solvents such as mineral spirits, and alcohol  which  present  two concerns:  accidental  inhalation  and flammability.  Flammability makes them additionally hazardous.  Environmental Issues. The Environmental Protection A c t ( E P A ) contends that the chemicals in paint waste such as P C B ' s , lead, and toluene contribute to low level ozone production and the formation o f smog ( E P A . Source:http://www.ilsr.org.carbo/ps/factsh03.html).  Some o f the hazardous  substances are substitutable with environmentally sound materials that are easier to handle.  Substitution and doing away with non essential ingredients would be a move  towards source reduction o f deleterious substances.  Economic Issues A Pilot Project for Managing Waste Paint In the early 1990s, the province o f British Columbia formally acknowledged the deleterious nature o f waste paint on the environment and decided that such waste could not be discarded i n the same way as general trash any other trash. Between 1991-1993 the Ministry o f Environment, operated a government funded pilot project for collecting and treating residual paint prior to landfilling. The facilities cost the provincial government a million dollars a year to operate and yet collected only a fraction (between 2-8%) o f unwanted paint generated by B C households. The remaining 92-98% continued to be either poured down the drain into local sewer  9  systems from where it migrated into rivers, or was collected at the curb as municipal waste and went into regular landfills.  A l l aspects of waste paint management, from  public education to the disposal o f non recyclable or reusable paints combine to present a major funding problem (Waste Reduction Commission, 1993:6). The failure in the pilot project resulted in a policy shift with regards to hazardous waste management i n British Columbia. •  It was decided that government cannot and should not pay for disposal o f household hazardous wastes such as paints and solvents  •  Systems based on government funding for disposal do not encourage reduced consumption. They actually make it easier for the public to use hazardous products by insulating the users from the real costs o f disposal  •  The financial burden for disposal is put squarely on the backs o f general taxpayers rather than the specific users. Responsibility must be imposed on the sectors which contribute to the problem and which are in a position to bring about change (Waste Reduction Commission, 1994).  Meanwhile, the volume of garbage generated continued to increase and pressure was on municipalities and the Ministry of Environment to 'deal' with the problem o f how best to manage waste- especially paint waste which could no longer be disposed o f i n the municipal waste stream.  10  A New Policy for Managing 'Waste' Paint The Post Consumer Paint Stewardship Regulation (BC Reg.200/94)  The Post Consumer Paint Stewardship Regulation (referred to hereafter as the regulation) was designed to complement the Waste Management Act. The regulation came into effect on September 1, 1994 and applies to every brandowner and seller o f consumer paint products in British Columbia. A copy of the regulation has been enclosed as Appendix 2.  The major objectives of the regulation are to (1) reduce the volume o f paint entering the landfill (2) force the paint industry and consumers to pay the disposal costs o f residual paint. The means objectives include the paint industry taking full responsibility for managing post consumer paint by designing a stewardship program, funding (or securing other  sources  for  funding)  and  operating  http://www.qp.gov.bc.ca/stat_reg/regs/elp/r200_94.htm).  the  program  (Source:  The following are some o f the  highlights o f the regulation:  1. Duties of the Brand-Owner A brand-owner is forbidden to sell, offer for sale or otherwise distribute, either directly or indirectly, a consumer paint product in British Columbia unless (a) the brandowner operates an approved stewardship program, (b) the brandowner, or the person operating an approved stewardship program on behalf o f the brand-owner, must treat, contain, recover energy from, recycle or reuse all post consumer paint within six months after collecting or receiving the post consumer paint at its return collection facility.  11  2. Report to the Director B y way o f monitoring the program, the Ministry o f Environment requires annual reports detailing the effectiveness of the brand-owner's stewardship program. The reports must include the following: (a) the total amount o f postconsumer paint products collected; (b) the total amount o f post-consumer paint processed or i n storage (c) the percentage o f post-consumer paint that was treated or contained, utilized for recovery of energy, recycled or reused, including efforts taken through marketing strategies to reduce post consumer paint and packaging waste;  3. Provision of Educational and Consumer Information Brand-owners must provide free o f charge information which informs consumers about the return collection facilities; the environmental and economic benefits o f participating in the stewardship program.  4. Liability A n y brand-owner who contravenes these requirements might be forced to pay a fine not exceeding $200 000 or w i l l be forced to stop selling, distributing or otherwise offering for sale consumer paint products in British Columbia. (Electronic  version  of the Post  (Ministry of Environment at  Consumer  Paint  Stewardship  Regulation.  Source:  <http://www.qp.gov.bc.ca/stat_reg/regs/elp/r200_94.htm>).  Paint Industries Comply with the Regulation There are over 30 paint 'brand-owners' based all across North America who are affected by the new regulation. Rather than setting up individual programs, brand-owners opted  12  collectively to set up the necessary regulation.  organizational framework to comply with the  The British Columbia Paint Care Program ( B C P C P ) is a non profit, industry  -run program which was created for the safe, effective collection o f leftover household paint and solvents (Ecofee Brochure: Consumer Product Stewardship Program. Dec. 1997). The Paint Care Association ( P C A ) , a non profit organization was established to manage the Paint Care Program on behalf of its members.  The Ecofee A second major requirement o f the regulation after the stewardship program  requisite is  for the industry to fund the program. In compliance with the latter requirement, the industry came up with the an 'ecofee' as the main funding mechanism for the consumer Product Stewardship Program (see Appendix 3 for ecofee rates). Amanda Diedrick (Director of Communications B C P C A ) summarized the rationale for the ecofee as follows: Rather than burying program management costs into higher product prices, the CPSP has created a separate ecofee which clearly indicates to consumers the costs associated with managing leftover hazardous products. The ecofee is a user pay system which ensures that only consumers who use a product help fund the costs of collection, transportation, recycling or safely disposing of leftovers.  The ecofee is a cost based fee: •  collected from consumers by retailers and brand-owners o f paints and solvents in B C  •  remitted by retailers and brand-owners to the Paint Stewardship Program to funds its province-wide collection and disposal program  •  is not a government tax. It is in essence a portion of the price of a can of paint but it is disclosed as a separate line on the sales slip to remind consumers of the costs  13  associated with the safe management of left over products. It is i n the best interests of consumers to generate less residuals i n order to reduce the costs of running the paint program - lower operating costs translate to a small ecofee charged per can of paint.  (Ecofee Brochure: Consumer Product Stewardship Program.  Dec. 1997).  The paint  stewardship program has been in place since 1995.  Objectives of the Post Consumer Paint Stewardship Program 1. Diverting paint from municipal waste stream •  Consumers are forbidden to dispose o f paint products into the municipal waste stream  •  Consumers are required to return unwanted paint to a depot  2. Implementing the polluter pays principle •  Consumers pay an industry tax (ecofee) to fund paint management program  •  Industry designs and runs the program using ecofee funds  3. Minimizing environmental impacts of post consumer paint by •  Reusing paint discarded by consumers  in order to prolong usefulness and m i n i m i z e waste  generation. This move could also result in a reduction in the amount o f raw materials needed to create a new product. •  R e c y c l i n g the paint that cannot be reused. Recycling has the potential to create raw materials for other products e.g. roofing and building products.  •  Recovering energy is important. Energy is recovered from the solvents in paint and is used in the ovens- resulting in a reduction in the volume o f new raw materials that would otherwise be required to produce the energy in the manufacturing o f a new product. .  •  4.  Treating paint prior to disposal in order to reduce pollution o f air and water resources  Providing Consumer Education •  Educating consumers about the impacts o f paint on the environment  •  Appealing to consumers to purchase just enough for the paint j o b  14  I was interested in knowing i f these objectives are being attained. The next section describes the methods used to get the outcomes of the program.  RESEARCH METHODS The "Program Theory" Theory provides not only guidelines for analyzing a phenomenon but also a scheme for understanding the significance o f research findings.  Chen (1990:17) defines program  theory as a 'set o f propositions regarding what goes on in the black box during the transformation o f input into output; that is, how, via treatment inputs, a bad situation is transformed into a better one'.  One of the bad situations in the topic at hand is that  residual paint was being improperly disposed o f into the environment causing different kinds o f pollution and damage. The black box in this case involves the processing o f residual paint into different products, energy retrieval, and treatment prior to disposal in order to diminish the impacts o f paint on the environment. Wholey (1987:78) asserts that the purpose o f program theory is to identify 'program resources, program activities, and intended program outcomes, and specifies a chain o f causal assumptions linking program resources, activities, intermediate outcomes, and ultimate goals'. "The Post Consumer Paint Stewardship Program Theory" The theory behind this program is that the creation of an enforceable product stewardship program should compel the paint industry to take responsibility for the products it manufactures.  The program  is  anticipated to result in the manufacturing of products that are environmentally benign in order to avoid the costs of special disposal.  In an attempt to reduce costs of waste management, industry will implement  waste reduction strategies. The ecofee charged to consumers should remind the latter of the costs of safe disposal of the products they consume. become aware (through the Consumer environment.  As well, consumption patterns will likely change if consumers Education  Program) of the  impacts of their habits on  Such strategies are in keeping with the goals of sustainability.  15  the  This is what I understand to be the paint stewardship program theory.  What I attempted  to do was to test this theory once I gave it substantive content, and to explain the outcomes o f the test.  Specific Research Objectives and Questions The purpose of my fieldwork was to explore the outcomes of the paint program with a view to determining whether the objectives of the program and the principles of product stewardship are being attained. The research questions which guided me i n the fieldwork include: •  What intended and unintended outcomes have emanated  specifically from  the  program? •  Have consumers positively changed their purchasing and consumption habits following the Consumer Education Program provided by the paint industry?  •  Is the ecofee enough of an incentive to encourage consumers to bring residual paint to the depots as opposed to disposing o f paint some other way?  •  Are the principles o f product stewardship being pursued in this program?  Prior to carrying out the fieldwork, I identified the following major actors in the post consumer paint stewardship program and interviewed them to get a general sense o f the program, the roles played by different actors and the workings o f the program. T h e M i n i s t r y of E n v i r o n m e n t is responsible for enacting the Post Consumer Paint Stewardship Regulation which led to the creation of the program whose outcomes I assessed. The Ministry monitors the program to ensure the requirements o f the regulation are being met. I consulted several times with Officers at the Municipal Pollution Prevention Department in Victoria who are the overseers o f the stewardship program in British Columbia.  16  The Paint Industry is a major actor because the regulation was specifically designed to force the industry to take certain measures to address the problems o f post consumer paint. The Paint Care Association ( P C A ) operates the stewardship program on behalf o f all brand-owners selling paint in the province of British Columbia.  The P C A was an  important source o f information. Environmental Organizations e.g. Recycling Council of British Columbia ( R C B C ) and the Greater Vancouver Regional District ( G V R D ) have endorsed the application o f stewardship to residual paint. They play an important role i n educating the 'public' and lobbying the government to enact laws such as the Post Consumer Paint Stewardship Regulation. Paint Consumers are key actors because the success o f the program depends to a large extent on consumer response in terms o f taking unwanted paint to a depot for eventual processing. Paint Collection Depot Owners/Operators: consumers return leftover, unwanted paint to a depot where the paint is stored prior to being transported to a paint processing facility in Surrey. See Appendix  for a list o f depots in the Vancouver area.  Each o f these actors provided me with information that I have incorporated in this thesis. Initially, I conducted interviews with the actors to get a comprehensive understanding o f the program. Having collected very general information I then conducted structured interviews with the actors (except consumers)  to get answers to the research questions  R C B C is a non profit organization which promotes waste avoidance initiatives in the province of British Columbia. The G V R D is a partnership of the 18 municipalities and two electoral areas that make up the metropolitan area of Greater Vancouver. The G V R D provides the municipalities with essential services that are regional in nature e.g. water, solid waste management, sewage treatment etc. 2  17  noted at the beginning o f this chapter. I conducted a consumer survey specifically to get answers to questions 2 and 3 as well as to get a general sense o f how consumers are affected by the program and in turn how they affect the program. The survey was a series of questions for which I needed answers to; clarifications and an insight into consumers thoughts and attitudes regarding some o f the objectives o f the Paint Program. The survey was carried over a three day period.  I approached paint  consumers at three different paint stores located in Vancouver, Burnaby and N e w Westminister. I asked the questions and wrote down the responses and comments each respondent gave.  Limitations of the Research Methods 1.  Considering that there are probably thousands o f household paint consumers in the province, sampling 50 respondents was not the best way to get  representative  opinions on the topic. Surveying a larger number o f consumers (at least some 500 consumers) would have provided me with diverse answers reflecting the 'real opinions o f paint consumers'. 2.  Since a number o f prospective respondents declined to answer the survey, possible that those  who chose to answer my questions  it is  were all 'generally  environmentally friendly folk'. This would explain why the majority o f respondents were in favor o f the program and what it stands for. For example, a majority o f the respondents said they would bring in residual paint for processing even without having paid an ecofee at the point o f sale. A door to door survey might have resulted  18  in diverse answers and would have reflected the perceptions of a greater number o f household paint consumers.  Criteria for Assessing if the objectives of the program are being achieved With the objectives o f the paint program and research questions in mind, I devised a criteria by which to assess aspects o f the paint stewardship program. 1.  Criteria for Assessing the General Performance of the Program  The effectiveness of the paint program w i l l ultimately be measured by how much it reduces not only the generation of left over paint but as well the volume of left over paint poured down sewers or thrown into municipal waste stream.  The overall  performance can be assessed by whether there is a gradual decrease (after about 4-5 years) or increase in the volume o f paint (in equivalent liter containers) brought in for processing compared to the volume o f paint sold annually throughout B C . A gradual decrease in returned paint suggests that people are using more o f their paint or that the program is successful in the sense that consumers are tending to purchase no more than they need. This in turn implies the Consumer Education Program is effectively serving its purpose. A gradual decrease however, might also be interpreted to mean that consumers are losing interest and not bringing residual paint to the depots. A continuos increase (5 years after the program has been in place) in the volume o f paint returned for processing can be interpreted to mean any of the following: 1) consumers are increasingly becoming aware (presumably via the consumer education program) o f the paint stewardship program and are interested in participating in terms of material  19  recovery; 2) maybe due to factors such population growth, new land developments, renovations etc. which necessitate paint use, a lot more residual paint is being generated some o f which is being brought to depots for processing.  2. Criteria for assessing whether the volume of paint disposed of in landfills  has  decreased since the program took effect.  What is needed to carry out this assessment is to compare the volume o f paint landfilled prior to and after program implementation. A decrease suggests the program is having a positive effect. If the volume of paint landfilled prior to the implementation o f the program is unknown, the volume of paint landfilled from the onset of the program could be compared with the volume o f paint landfilled yearly after the program is in place. 3. Criteria for Assessing Environmental Protection  A s far as the objective of environmental protection goes, I think it is important to prioritize the means objectives of the paint program. Doing so ensures the  most  effective means to attaining the objective is utilized first to get the best results. In my judgment, environmental impacts of post consumer paint w i l l best be minimized by (a) reducing as much as possible the volume of paint that becomes unwanted (b) reusing left over paint rather than disposing of it into the environment (c) recycling paint into other products such as roofing and building materials (d) recovering energy from residuals that cannot be reused or recycled (e) treating polluted paint, stabilizing it and landfilling Managing residual paint in this particular order, which is acknowledged by authors such as Grady (1993:45) w i l l to a greater extent, reduce the volume of residual paint.  20  For this reason, the hierarchy described should be observed of the paint stewardship program for it to lead to meaningful environmental protection.  If the hierarchy of  activities being implemented by the paint program does not resemble the above hierarchy then questions should arise about the effectiveness of the program in terms of environmental protection. 4. Criteria for assessing the effectiveness of the ecofee as a mechanism for making the 'polluter pay' and encouraging consumers to adopt environmentally friendly consumption habits.  The application of a polluter pays principle can be said to be successful i f all the costs of the paint program are being paid solely by the 'polluters' e.g. industry and consumers. In the case of the paint program, consumers pay the ecofee while industry runs the program. A s such, the two groups of polluters have taken responsibility for 'waste' paint. The ecofee is a valid stewardship mechanism i f the funds raised are used to process post consumer paint effectively or to pay for changes in current industrial practices and ultimately in eliminating environmental concerns associated with paint.  A secondary  criteria which might be considered for assessing the effectiveness of the ecofee is i f consumers' purchasing habits positively change specifically because of the ecofee e.g. if consumers are now more careful to purchase only the required volume of paint and not more than needed.  21  RESEARCH FINDINGS Difficulties Encountered During Data Collection  When I started collecting information about the paint program, I wanted know how much paint was distributed (sold) in each month or year to enable me to compare returns by volume of new paint that consumers have. O f the five paint manufacturers/ distributors that I contacted in the Vancouver area, none o f them were willing to disclose this information to me. The reason given was that 'this is proprietary information you are looking for. I can't just give it to you...'.  Another manager explained, 'from a  competitive, strategic viewpoint, I don't think any of the companies w i l l part with that information. The P C A can however, give you an aggregate figure to work with'.  Only  two manufactures agreed to give me a rough idea about how much paint they sell annually in B C . The two figures were: half a million gallons and 'about 800,000 gallons, maybe'. I contacted the P C A numerous times but they insisted they 'do not know and in-fact do not need to know that information'.  The Pollution Prevention Branch in Victoria also  explained that it does not have that kind of data. According to the Ministry o f Environment, there is no real need to know how much paint is sold. For example, lets say 10m equivalent litres o f paint were sold i n 1997 and in the same year, 2m litres of paint were returned to the depots for processing. D o these figures necessarily mean that 8m litres o f paint were totally used up during 1997? Maybe. It is also possible that a portion o f that amount has been stored for later use or has been poured down the drain. In some cases maybe the paint job has not even been done yet. The important question according to Jim Marr of the Pollution Prevention Branch in  22  Victoria is: Is there any unwanted paint and i f so, how is it being managed or disposed of? This is where the paint stewardship program kicks in- to take care o f the paint that is unwanted. In my judgment, it is absolutely necessary in order to assess the achievements o f the paint program, to know information such as the volume of paint sold, the volume o f paint that was dumped into the environment prior to this program and the degree o f pollution that resulted.  K n o w i n g the total volume of paint sold throughout B C annually might have  given the following insight into the program: •  i f the amount sold is decreasing and the amount returned is going up then it could be concluded the program is having an increasing effect  •  i f the amount sold is going up and the amount returned is going up i n proportion then it probably means the effectiveness o f the program has peaked.  •  to really assess program effectiveness I probably needed these three things: 1. amount sold 2. amount used 3. amount unused a. dumped b. returned to depot  The Post Consumer Paint Stewardship Program regulation states that 'the Director may withhold sales and financial information that the director considers w i l l place the brandowner  at  a  competitive  http://www.qp.gov.be/ca/stat_regs/elp/r200_94.htm).  disadvantage" Since the  regulation  (Source: allows  a  Director i n the Ministry o f Environment to withhold some information, it is possible that there is a lot more data than I was able to procure. A s such, given the very sketchy data I  23  was working with, my assessment and analysis of the program w i l l likely differ from another researcher's analysis i f the researcher has access to the information that is currently  in the  hands o f a Director in the Ministry o f Environment.  sections describe my rather sketchy research findings.  24  The following  Map 1: Residual Paint Collection Facilities in B C (100)  Map l illustrates the depots that have been set up throughout BC for paint collection. O f the 100 depots in the province, 20 are within the lower mainland- because of a higher percentage of consumers. Up North, the depots are dispersed.  25  Graph 1 Monthly Paint Collection 1995-97 400,000  o l J  , F  « M  , A  ,  ,j M  J  . J  • • • • •• A  S  O  ,  ;  N  D  I  (Source: data obtained from the Pollution Prevention Branch, Victoria).  Graph 1 shows the monthly volume of residual paint collected during the last three years. During the summer months, paint jobs increase and so does the volume o f unwanted, leftover paint that is brought to the depots. Note: the volume o f paint collected each month has been increasing over the years (See p. 27 for possible reasons for these increases).  26  Volume of Paint Collected 1995-1997  2,500,000  J3 e o  o  2,000,000  - - 4 <f  1,500,000 .  * ' 5 -. 1  1,000,000 cr Hi  500,000  IpSll  - . - *; v • - • 1  -: ; -  0. 1995  --•  Ijjlll  •'  1996  1997  (Source: data obtained from the Pollution Prevention Office, Victoria).  Graph 2 shows the volume o f leftover paint collected annually. The question is; why is the volume o f paint brought to depots increasing? I expected higher volumes i n the first two years as consumers became aware o f the program and started bringing their old and more recent unwanted paint. I expected a gradual decrease in 1997 as old paint disappeared from consumers' basements. A s well, I anticipated that because o f the Consumer Education Program which appeals to buyers to purchase no more than they require, that there would be less leftover paint to be brought to the depots. But the results show the contrary! The increases in volume of unwanted paint brought to the depots each year could mean two things: The paint program has as yet not reached a 'steady state'. Consumers who have stored paint i n their homes are gradually becoming aware o f the program and are returning their  27  relatively old, residual paint. The volume o f unwanted paint w i l l presumably taper off after a few years. Could it be that for a variety o f reasons, consumers are still buying more paint than they need and this coupled with the rush to bring older residual paint to the depot is resulting in drastic increases in the volume o f paint coming in each year. One o f the reasons why consumers might be buying more paint than they require is because while a 1 litre can is sometimes not enough for a 2 litre paint job, a 4 litre pail is. A s such, with or without the ecofee a consumer w i l l end up with 2 litres left over. Other reasons for the increase include the fact that B C ' s population is rapidly expanding and so is the rate o f construction of new homes. This increases the volume of paint sales which in turn could result in increases in the volume of residual paint generated annually. A s well, it is possible that the rate of renovations has been increasing over the last few years- giving rise to increases in the volume o f paint both sold, used, unused and brought to the depots for processing. If the latter speculations are a true picture, then the educational program appealing to consumers to purchase no more than they need cannot on its own significantly reduce the volume o f leftover paint. Given the limited resources and time frame o f this project, I was not in a position to carry further research to determine the age o f paint brought to the depots. Doing so would give an insight into how much of the residual is backlog paint and how much is relatively new paint. A higher percentage o f relatively new (about three years or less) o f residual paint would confirm that consumers are still purchasing more than they need. The only consolation at this point is that all this paint is not being poured  28  down sewers or going into the conventional waste stream but is being recycled, reused or treated and safely disposed. A s well, because of the difficulties encountered in obtaining information regarding the total volume of paint sold and used annually, I cannot say for sure whether any less paint is being dumped.  29  A summary of the possible explanations for the increases and decreases in the volume of residual paint collected after the first five years of the program Gradual Decrease  Consumer Education Program has been effective  Consumer Education Program has been relatively ineffective  Consumers fully/ almost fully utilize  Consumers have lost interest in program  the paint they purchase  • Little or no residual paint  Little or no residual paint brought to depot  I Residual paint is probably  /  1  poured down the drain  stored  \ discarded into municipal garbage bins  GRADUAL INCREASE  Consumers are aware of program and are interested in bringing residuals for processing but are still purchasing more paint than they need  population growth  new land development  \  \  renovations  Results in increased paint sales Consumers are aware of program and are interested in bringing leftovers for processing  Continuos increases in the volume of  Sustained increases in the volume of  residual paint brought in for processing  residual paint brought in for processing  30  Fig. 3 Post Consumer Paint Processing 1997  Energy recovery 30%  Recycling 51%  Landfilled 11% Reuse 8%  (Source: data obtained from the Pollution Prevention Office, Victoria)"'  Graph 3 illustrates a breakdown o f the types and percentages o f processing o f residual paints. A t first glance, what seems peculiar with these results is the waste management hierarchy (refer to criteria # 2 or Appendix \) occurring in reverse order. Reduce and reuse are the first two o f the 3Rs approach to waste management but for the paint industry, the last o f the three Rs is more prevalent- 51% of unwanted paint is recycled (into products other than paint). Recovery has assumed a place next to recycling and yet its place i n the waste management hierarchy is at the bottom because o f its relatively l o w beneficial impact on environmental improvement.  4  What is equally unsettling about these results is that more paint is being landfilled than reused. This however, can be explained in part by the fact that any paint ten years or  the units for measuring the quantity of residual paint brought to the depots is in equivalent litre containers. This means residual paint is measured by number of cans that are received at the depot and not the actual volume of paint in the containers. The container has to be at least three quarters full and meet the requirements described on p. 33 for the paint contained inside to be approved for 'reuse'. Reusable paint refers to surplus paint that is totally in good condition and which is suitable for reselling and which is brought to the depots as unwanted paint. Energy is recovered mostly from solvent. The energy is used for the plant's paint ovens. 3  4  31  older that comes to the depot likely contains toxics (which have been phased out in more recent products) or is contaminated and can not therefore be recycled or reused. Landfilling is the only way o f dealing with such paint. I expect that the volume o f waste being landfilled prior to any other type of processing w i l l gradually decrease as old paint disappears from consumer's homes.  Why is there no widespread re-use of paint? A mere 8% is being reused. It turns out reuse is constrained by the following factors: paint older than ten years is non-reusable - so is paint that has been frozen, or improperly stored (improper storage such as outdoor storage will likely cause corrosion and affect the quality o f the contents). Paint is reusable and made available free o f charge to the public if: •  it is in good condition with no apparent rust or damage  •  the l i d must be sealed with no excessive paint in the rim  •  original manufacturers label must be readable, not be obliterated by paint container must be full or nearly full ( within two inches o f the inside top rim) or weigh 91bs (4 litre can).  Given these requirements, a significant portion of paint that reaches the depot is nonreusable.  This might not be the only explanation for why the level o f reuse is low. It  appears those who drafted the regulation anticipated and indeed are comfortable with a low rate of reuse. The regulation states that a manufacturer is required to 'treat, contain, recover energy from, recycle or reuse all post consumer paint...". Reuse is presented as a last recourse when all logic points to reuse as a priority in any genuine attempt at  32  improving the state o f the environment. Is it possible that the role o f the second R has been undermined because cans would have to be opened, colors checked, more spills and more toxins encountered. Would brand-owners be willing to pay for those risks, as well as increased handling fees?  The problem with recycling paint and with recycled paint  Graph 3 shows that 51% o f paint processing involves the recycling o f paint into products other than paint.  Recycling paint into paint has been tried but several constraints and  problems arose which led to the cessation. Not only were there problems associated with recycling paint, other issues arose with the paint that had been recycled: •  The recycling option where it exists, is essentially limited to latex paints. A l k y d paints because o f the complexity, variety and potential incompatibility of their formulations, do not lend themselves to recycling. But even with latex, there are constraints. It is very 'sensitive' paint; freezing ruins it. While some manufacturers recycled some products successfully, others experienced problems ranging from possible conflicts with environmental or transportation regulations to contamination o f paint equipment, due to bacteria or accidental 'cross contamination' of latex with o i l paint, which ruins the  blended  latex  (Source:  National  Paint  &  Coatings  Association  at  <http://www.paint.org/apr95.htm>). •  Manufacturers soon learned there was no market for recycled paint.  Frances  Cairncross, environment editor o f The Economist surveying European and American companies about their recycling initiatives found:  33  that landfilling is cheap and recycling is expensive, in part for lack of markets for recycled materials... Voters appear to love recycling. It seems to meet some deep human need to atone for modern materialism. Unfortunately people do not seem to feel quite the same craving to buy products made of recycled materials.  The brief survey I carried out at paint stores with a total of 50 household paint consumers as respondents provided an insight into why this group o f consumers is not keen to purchase recycled paint (refer to Appendix 4 for a copy of the survey and for summary and commentary of the responses). 48 % of respondents said they would not buy recycled paint 8 % said they could consider purchasing recycled paint only for certain things e.g. paint for the dog house; to use for graffiti etc. 7 % said they would opt for recycled paint i f it was made available at a cheaper price The rest o f the respondents either had no comment or not sure. Although some respondents were not aware of the existence o f recycled paint, they were quick to conclude that they were not likely to purchase it. 'When I do a paint job', one respondent said, 'I want it to last. Recycled paint is of inferior quality and there are no guarantees with it'. Then there is the matter o f market economics. Recycling paint into paint currently costs around $7.20 per gallon, including the costs of collecting, identifying, segregating, testing and adding new raw materials. Selling for an average price o f $2 to $7- the amount the typical market w i l l bear- the recycled product obviously does not pay back its processing cost.  National Paint Care Association ( N P C A ) believes there is a role for voluntary  recycling (paint into paint) in the hierarchy of waste management but that it must not be mandatory for any manufacturer.  34  Recognizing the Limits to Recycling The positive aspects o f recycling include conserving materials which would otherwise have to be replaced. More importantly perhaps, recycling reduces the process energy required to manufacture new products. But often these benefits are offset by other throughput costs. It is tempting to think o f recycling as an air tight system, in which the recycled materials are funneled back into the system with perfect efficiency. Rees emphasizes explains that it is impossible to recycle with 100% completeness. N o t only is some material lost in each cycle, but the process o f recycling itself creates its own set o f throughput demands which must be counted against the savings from recycling (Course: Plan 504, School o f Community & Regional Planning: U B C ) . According to Ackerman (1997:158) the environmental goals that motivate recycling are often best served by less rather than more recycling- that is, by preventing the generation of waste in the first place. The 'hierarchy' of integrated waste management, advocated by the E P A and many state agencies also place waste reduction at the pinnacle, the most environmentally desirable approach o f all. M y point in citing these remarks is i n support of my argument which is that recycling half the 'waste' paint brought to the depots does not solve the waste problem. But rather that more reuse would be beneficial.  Treatment/ Containment: About 11%) o f post consumer paint brought to the depots is treated, solidified (stabilized) prior to disposal into certain landfills that are lined to ensure environmental safety. According to the Communications Director o f P C A , the landfills are outside B C ! The type o f paint that is being landfilled is supposedly that which is older than ten years and  35  therefore contains several toxics. A l k y d paints are likely to be incorporated into a fuel blend and sent to an incinerator.  Is the Polluter Pays Principle Working? The objective o f shifting 'waste' management costs from taxpayers to consumers and producers o f a product that becomes a pollutant has in my opinion been attained. This is evidenced by the existence o f a fully operational system for processing unwanted paint. The system is managed by the paint industry and is funded by the ecofee obtained from consumers. I was informed that the program was operated at a cost o f $2.7 million in 1997. The 1997 figure is slightly lower than the costs of the first two years. According to the P C A , the industry has succeeded in lowering the costs o f operating the program despite increasing volumes o f paint brought in for processing. It is expected that the volume w i l l decrease once the backlog residual paint has been processed. Representatives o f the B C Paint Care Association would not disclose the total amount o f ecofee collected annually. I was interested in knowing whether the ecofee collected each year is all used up by the program. P C A ' s refusal to disclose this vital information opens up several questions. For example, I wonder i f the industry is profiting in some way from the ecofee because even though the fee is charged on all paint sold, only a small portion of the paint becomes residual and of that small portion, the P C A strongly believes only a relatively small amount is returned to the depots.  The P C A ' s response to my query was  that consumers who purchased paint prior to 1998 did not pay an ecofee yet they are  36  encouraged to return residuals to the depots for processing and clean disposal and these activities are funded by the ecofee. Since the Paint Care Association would not answer all my questions, the following remain unresolved: Assuming there is a surplus ecofee, how w i l l the paint industry be accountable for the use of the money that w i l l be accumulated in surplus revenues from unclaimed 'deposits' and other sources? In the surveys that I conducted, I asked i f consumers considered the ecofee an incentive to bring residuals to the depot for processing? yes.  Out of 50 respondents, 27 answered  15 respondents said they would bring in residuals even without having paid the  ecofee i f a program were in place to process unwanted paint.  8 respondents said they  were not quite sure i f the ecofee factors at all into decisions about whether or not to bring residuals to a depot. These results suggest that the ecofee or the application of a polluter pays principle has generally not served as a mechanism to  encourage  consumers to participate in the paint program. It appears they would have done so even without this mechanism. Given this finding, it can be concluded of the paint program that on the one hand, the ecofee has not served as an incentive to encourage consumers to return unwanted paint and on the other hand, it is serving as the funding mechanism of the program. On the question o f whether consumers feel the ecofee is a worthy charge, the general perceptions o f the 50 respondents were: "I think the ecofee is a worthwhile charge. The only problem is there is no knowing for sure i f all the money goes into the program or some place else".  'Paying environmental fees is a noble gesture but it can be  37  disheartening because there are no concrete measures of progress to illustrate whether or not the state of the environment is actually improving because of a particular activity". In response to these sentiments, Dave Douglas o f the Pollution Prevention Municipal Branch in Victoria explained, When we didn't have this program which is funded by the ecofee, it is possible that these 3 million equivalent litres of paint (the residual paint that has been collected so far ) would have been dumped onto the environment. Imagine the magnitude of pollution that would occur. People tend to not think about the repercussions of waste paint on the environment because of the dispersed nature of the problem but the problem does exist... One of the greatest hurdles to environmental protection is funding. The ecofee allows for environmental protection measures that would otherwise not be undertaken because of lack of funding...".  M y take on this question is that the ecofee strategy for funding environmental protection measures and for improving economic efficiency by reducing distortions i n the economy is a positive idea. The fee is potentially an enabler of change in the sense that funds are now available as Douglas mentioned, to eliminate environmental concerns associated with unwanted paint. I think the fee is a valid stewardship mechanism i f the funds raised are used to manage the specified products and i f consumers change their practices because of the ecofee. In the case of post consumer paint, it is clear that the fee funds the program and is in that respect, an effective mechanism for environmental protection. There is no evidence to suggest or to not suggest that there is an ecofee surplus. If a surplus exists, it would be interesting to know how it is utilized and by whom and questions would arise about  38  whether consumers are being made to pay 'a lot more' than is required for the safe disposal of residuals!  OTHER OUTCOMES Other outcomes which are not explicitly stated as objectives o f the paint stewardship program include:  Employment Creation The Ministry o f Environment has designated a couple o f employees to monitor the program. The B C Paint Care Association and the Consumer Product Care Association employ a number o f administrative personnel to run the program. A s well, there is interaction between big business (paint industry) and grassroots, local level businesses (e.g. Joe's  Bottle Depot). The paint industry has  contracted the  collection  and  transportation o f residual paint to small local based businesses.  The Availability of Free Paint On average, about 8 % of leftover paint brought to the depots for processing and disposal is set aside as reusable paint i f it meets the conditions set for reusable paint. The paint is made available free o f charge to the public through the paint exchange program. N o n profit organizations and low income persons in particular have turned to the exchange program for paint.  Influence of the paint program on other groups Other provinces in Canada and the United States are paying close attention to the outcomes of the program in order to decide whether to implement a similar program. Inadequate data and the difficulties observed in terms of monitoring the program are  39  important challenges which anyone interested in replicating B C ' s paint program w i l l have to carefully consider.  Other types o f industries are also looking at the performance o f  this program. They are aware that product stewardship regulations w i l l likely be forced on them at some point. The residual paint program and its outcomes is giving them an insight as to what to expect. Epstein (1996:33),  is convinced the 'take back' approach w i l l force manufacturers  everywhere to rethink their activities and be more environmentally sensitive to the supply chain.  Writing about product stewardship initiatives in Europe he further  explains  many  that  companies  are  concerned  that  if  they  do  not  become  environmentally sensitive, they w i l l not be able to sell their products in various countries,  including  most  of Europe because of various European Community  initiatives along with emerging requirements of the International Organization for Standardization (Epstein, 1996:33).  An Analysis of the Program and Research Findings  Having examined the outcomes o f the paint program with the results described in this Chapter, I identified certain issues or areas which needed further discussion in order to enhance the overall clarity o f the study. The research findings and their implications on environmental protection are explored towards the end o f the chapter.  40  1.  Is there a need for this specific program whose importance might diminish with  time?  Prior to the regulation, the Ministry o f Environment surveyed a 1000 people about whether they had unwanted leftover paint in their homes (Source: National Paint & Coatings  Association  at  <http://www.  paint.org/apr95.htm>).  T w o thirds  of  the  respondents reported having unwanted paint- the average amount was only about a litre. These findings suggest the 'waste paint problem' is not as immense as some authorities believe.  While gathering some initial information about the program, I was convinced  neither the Paint Care Association nor the Pollution Prevention Branch in Victoria were absolutely certain about the 'real' impact of paint on the environment. A manager at one of General Paint's stores explained to me that "hazardous ingredients such as lead (Pb) have pretty much been phased out". The National Paint & Coatings Association says of the paint program,  " while environmental concern has made it harder to throw  away paint, today's household paints are much more environmentally- friendly than those of the past, now that 75 to 80 percent of them are water based rather than solvent based" (Source: http://www.paint.org/apr95.htm). In response to my query about the relevance of a stewardship program when there is so much uncertainty surrounding the effects of paint on the environment, an Official the Ministry of Environment responded: ... you don't need certainty to act on environmental issues. The province cannot wait for proof beyond reasonable doubt- in other words, for actual deterioration- to substantiate a theory, if you wait until you see a measurable effect- on humans, plants and animals- you are going to be living with that effect for a very long time...  41  with  I am aware that in some cases evidence of environmental problems surface after a long time of unchecked pollution-causing activities and that it is wise to sometimes address a potential problem before it arises. Paint products have been in use for a long time. I would have appreciated  a full explanation and description of the  environmental  problems that have been caused by paint products. For example, it would have helped to know how much paint was dumped into the environment and the subsequent degree of pollution that occurred. But without such information, it is difficult to stand a hundred percent behind the need for this specific program. Based on the findings o f the Ministry of Environment's Household Paint Consumer Survey (described on the previous page), I wonder i f it was counterproductive to create an elaborate structure, mechanisms, and bureaucracies to deal with an issue that w i l l diminish in urgency over time. It might have been possible with successful educational efforts and consumer cooperation, to decrease and minimize future amounts o f left over household paint, without government  institutionalization of the paint  stewardship  program. Yet given the degree o f environmental degradation caused by post consumer products and industrial processes, it appears without government intervention pollution reduction is unlikely, except at levels that make economic sense to the firms generating the wastes.  2. Is Paint A "Waste"? The National Paint and Coatings Association strongly believes that paint is not a pollutant; to the contrary, it is a product that preserves and protects property, and in so doing, helps protect the environment.  A s far as the Association is concerned, paint is not  42  inherently a waste; unlike motor o i l or tires, it could be fully consumed, or saved for later use, rather than partly used and the remainder discarded. The Association questions how this product that prolongs the life-span of buildings and furniture, a product that can be fully consumed, or saved for later use become a waste, a pollutant? The answer seems to me to be that consumers are creating the 'waste' by failing to fully consume the paint products they are purchasing. For this reason, consumers more than the paint industry are at fault for the existence of residual paint and ultimately for the economic and environmental issues associated with residual paint. The key question is: W h y have consumers not made source reduction a priority? The key barriers to source reduction on the part of consumers seems to be both institutional and attitudinal. F o r example, we talk about conserving resources but at the same time we look to 'consumer confidence' as a key indicator of economic prosperity. B y taking on the fundamental ideals of the current market economy, we are inevitably driving around in circles -away from true 'waste' reduction. A s w e l l , there is the example of an elaborate post consumer program whose objective is to treat and dispose of wastes, not prevent their creation. This coupled by an indifference towards the impacts o f one's consumption habits on the environment are the two culprits to blame for the existence o f unwanted paint.  The post consumer paint stewardship  program is giving reckless consumers an opportunity to correct an irresponsibility.  My  contention is that while this action is remarkable in some ways, it is an end-of pipe fix that fails to prevent the problem from arising i n the first instance.  43  1 suggest more emphasis be placed on achieving near zero residual paint as doing so means a lot more meaningful changes w i l l accrue to the environment. A higher ecofee could be a more effective incentive to deter consumers from buying more paint than they need. A s well, a higher ecofee is more likely to remind consumers o f the costs associated with the safe management o f leftover products in order to reduce impacts on the environment. Where unwanted paint exists and source avoidance no longer applies the focus must shift towards compelling consumers to return residuals to a depot for processing. Although some consumers might return leftover paint because they have already paid the cost o f disposal (via ecofee), it is probable that other consumers never quite make it to the depot. A refund mechanism is an option that could be considered to encourage such consumers to get to a depot.  The refund mechanism has been successfully adopted by bottle  companies because it gives consumers a greater incentive (in my judgment) to participate in a program for material recovery. The Recycling Council of British Columbia carried out a study in 1992 to determine the factors that make the bottle deposit-refund system successful. The results detailed in the article, "The Anatomy of A Deposit System" in Reiterate. Oct.  1992 can be  summarized in one sentence — - It's the refund, the promise of a cash reward for bringing back empty containers, that drives the  'deposit' system.  There is no  conclusive evidence that over the long term education alone w i l l be as effective as the cash incentive for litter abatement'.  44  This study w i l l not discuss in any greater detail whether the largest volume of paint w i l l be recovered by means of a deposit -refund system as opposed to the current ecofee but I think this is one area that needs further study.  3. The critical role of the consumer A consumer education brochure informing the public about the repercussions o f 'our consumptive patterns on the environment' is often stashed on some wall in a paint store. A n appeal is made to consumers to change their consumption behavior.  While simple  steps such as returning unwanted paint to the depot count, questions remain about whether the behavior change resulting from initiatives o f this type is enough to affect environmental outcomes, and whether the behavior change is sustained.  Piasecki's  perspective on this issue is echoed by Ortolano, 1997:193; and Dwivedi, 1997: 80. ... the consumer society that has evolved over the past century is efficient at delivering whatever higher social expectations consumers want, including a cleaner environment. When the consumer wants environmental protection, the consumer will get it (1995:ix).  The successful implementation o f environmental regulation involves the cooperation o f citizens and industries. Given this 'fact', it is important in order to achieve environmental protection, to introduce effective education programs to equip consumers with a solid understanding o f the issues and solutions. Yet another flaw that I have found to be evident in the program planning is that no specific responsibilities have been attributed to stakeholders other than the paint industry. Surely some o f the responsibility for environmental protection belongs to others e.g.  45  consumers and local governments etc. Yet there is no evidence to suggest that the responsibilities have been discharged accountably. There is no assertive obligation or clear  economic  incentives  in place  to  encourage  consumers  to  participate  in  environmentally effective and cost-efficient waste management schemes. The regulation anticipates all action to come from industry which as w i l l be discussed later shows no 'real' desire to act effectively. Steveston in Extended Producer Responsibility. Canada's Magazine on Collection. Hauling. Processing and Disposal. V o l . 3 N o 1 Feb/ M a r c h 1998: 14. perceives the situation differently. H e contends that 'overwhelmingly, these new regulations (polluter pays principle and product stewardship) and financing schemes levy the charge directly and visibly on the consumer purchasing the product rather than on the industry producing the goods. F o r example, the 50 cent per gallon ecofee for each can o f paint sold in British Columbia is in addition to consumer responsibility for bringing back the post consumer product to the depot or collection site.  Steveston concludes, 'while  industry is responsible for running the programs, I wonder how much financial contribution they are making towards the programs! In the final analysis, I agree with Piasecki (1995:ix) that i f consumers decide they want a clean environment they w i l l take a stand against their own excessive waste generation patterns as well as against the wasteful practices of industries.  4. The Paint Industry and the Paint Program: An Analysis  The translation o f a stewardship concept into a program that has begun to yield results could be interpreted to mean the industry is sincere in its efforts to reduce the volume o f  46  paint that has to be landfilled. Yet a more in-depth inquiry into the way the industry is conducting business shows this is not necessarily so. O n the one hand, the B C Paint Care Program advocates buying only as much paint as you need, "so that we can all reduce the costs o f managing paint wastes". On the other hand, the paint industry sends a contradictory message with its pricing policy-  the volume discount (where a gallon of paint costs less than three quarters)  encourages consumers to buy more than they need.  The concept o f cultural restraint,  where educated consumers might drive less, package less, consume less, is essentially unmanageable for industries. They have built their hope on the sands o f ceaseless industrial progress, not the vigilance o f conservation and the high performance o f restraint (Piasecki, 1995:122).  This is reflected in part by the puzzling absence o f  reduction in the program outline. Ortolano (1997:95) argues that the success of a program depends on the decisions made about which o f many items on an agenda should be undertaken first. The cue is to figure out 'will the vision, the goals be achieved by starting at this or that point? For the residual paint stewardship program, reduction is undoubtedly the priority activity because o f its greater ability to virtually eliminate waste generation in the first instance. It appears the industry and regulators 'muddled through' to find solutions to environmental problems that are satisfactory, but probably not optimal. The Ministry of Environment for example, presumably sees no conflict for paint industries in carrying out these two tasks. The industry reveals its true attitude in the pricing system. F o r example, a litre of paint is sold at roughly $12 while 4 litres are  47  sold at the relatively low price of $25.  Consumers tend to not be able to resist such  bargains. J i m M a r r of the Pollution Prevention Branch in Victoria explained to me that industry's pricing system is one of the major obstacles to preventing the problem of residuals from occurring in the first instance. According to M a r r , " . . . consumers w i l l end up buying 4 litres even i f they only need 2 litres because it's cheaper and there is always the possibility that they might need paint some other day". Such sales bargains illustrate industry's objection to government policies forcing industries to modify their practices to reduce waste. One  of the major shortfalls of this program is that the Ministry of Environment i n  conjunction with the paint industry have created a program that cannot be evaluated based on what it has achieved or not achieved. Without knowing the kind of pollution caused by paint for example, how can one then assess whether the program is resulting in a decrease/ increase in the degree of pollution occurring? A s well, without knowing how much paint was dumped into the environment before the program was in place, how can one assess whether more or less paint is being dumped now that the program is i n place. The absence of critical data means that it is difficult i f not impossible to judge the level of performance of the program. Because the program can not be evaluated, both the Ministry of Environment and the Paint Industry have shielded themselves from possible criticism.  In many ways the post consumer paint program has not enough teeth to cause any changes i n consumers and the industry. F o r the paint industry in particular, an ecofee of a mere 50c per litre of paint is unlikely to influence consumers' purchasing and consumption habits. This means that the industry w i l l likely not suffer any major  48  decreases in paint sales. The puzzling aspect of all this is that the Ministry of Environment seems to be paying lip service to environmental protection by being involved in a social program whose achievements or lack thereof are unknown.  Implications of the Research Findings on Environmental Protection One o f the objectives stated for this study is an exploration of the implications o f the outcomes o f the program on environmental protection. Perrings (1987:99) contends  that free  disposal of residuals implies the physical  independence of the economy from its environment. One of the major achievements o f the stewardship program is that it has in theory, ruled out any notions of the physical independence of the economy from the environment by making consumers pay the cost of safe disposal and by forcing the paint industry to minimize the impact on the environment. In practice however, the physical independence of the economy from its environment is still implied. Although the paint stewardship program is meant to reduce impacts o f economic activity on the environment, the achievements of the program so far leave a lot to be desired. A s well, because o f the secrecy surrounding the measurable outcomes o f the program, 1 find it difficult to say how much better off the environment is with this particular program in place.  The difficulty in determining how much environmental  protection is going on lies mostly in the fact that there is no way o f knowing i f all consumers who have unwanted paint are bringing it in for processing. It is possible that some paint is still being poured down sewers or thrown in to the conventional waste stream. In fact, a poll done by R C B C concluded that there is 'no significant evidence o f  49  environmental protection. The province estimates that only 1-8 percent o f consumers who have residual paint actually use the service. The rest o f the population presumably continues to dump or stockpile its wastes' (Reiterate, September 1994:9). Disappointing as this result might be, critics such as R C B C president James Romano take a positive stance; Three million and a half litres of paint have found their way from people's basements and garages to be safely disposed of— or offered for 're-use' in paint exchanges. It will be a while before all the pieces fall into place. Nevertheless, its safe to say that without this program a lot more paint would be sitting on basement shelves — or polluting local waterways (Reiterate, February 1996:2).  Although there are no measurable effects of this program on the environment, I think it is reasonable to suggest that product stewardship initiatives, when well implemented, reduce the potential of environmental pollution from post consumer products and given time and positive changes in consumption patterns -  a reduction in throughput w i l l  likely occur. Piasecki  (1995:112) remains unimpressed by the achievements o f environmental  protective measures such as product stewardship. He concludes that 'neither landfilling, combustion, recycling, nor reduction by itself can solve the current waste management crisis. H i s assertion is that each (protective measure) amounts to less than the sum o f what's needed, leaving behind too much waste that is not managed properly'. Unlike Piasecki, I do acknowledge the salient outcomes o f product initiatives.  stewardship  In my opinion, the implementation of a stewardship program takes us a step  ahead in terms o f dealing with the waste management crisis. Lead (Pb) which was one o f the most troublesome materials in paints and solvents is no longer being used by the paint  50  industry because the government regulated against its use.  In summary the point I am  making is that one step is hardly enough of an achievement but then again, a step is better than no step.  RECOMMENDATIONS •  T o enable meaningful program monitoring and evaluation, it is important for the authorities in charge of monitoring the program, to collect data over time. Such data would  readily  illustrate  program  effectiveness  and  point  to  areas  needing  improvement. •  There is need to resolve the apparent conflict between the wording o f the regulation and the clear intent: the intent according to the Pollution Prevention Branch is to reduce paint waste but the wording o f the regulation and the way the program activities have been prioritized suggest that 'its okay to generate waste- but just make sure you bring residuals to the depot for processing'.  •  In order to dispel consumer skepticism about the way the ecofee is utilized my recommendation is for the P C A to use a visible costing system. F o r example, the P C A could make available to the public information regarding the total annual ecofee collections, listing the expenditures and providing information about the achievements of the paint program and the challenges being encountered. Such disclosure would solve the problem of consumers doubting or questioning whether their moneys are being spent on intended purposes. Consumers in turn have a responsibility to make those individuals who manage their wastes accountable for doing so in an environmentally and economically sustainable manner.  51  •  The sales bargains i n the paint industry have the effect o f counteracting the gains made through the paint program. When 4 litres of paint cost less than three litres consumers tend to buy the 4 litres even i f they do not require as much paint.  My  suggestion for counterbalancing this effect is for the industry to be forced to increase the ecofee according to the volume o f paint sold. Increasing the ecofee would make it a more effective incentive to deter consumers from buying more than they need. A s well a higher ecofee is more likely to remind consumers of the environmental costs o f the products they consume.  Conclusions  In attempting to advance the concept o f product stewardship as a feasible approach to waste management, I have examined the outcomes of B C ' s Paint Stewardship Program in order to ascertain whether the objectives o f the program are being achieved.  The  highlights o f the research findings include: 1. The objective o f making the polluter pay appears to have been achieved in theory. The paint industry is running the paint program which is funded by consumers. In practice, a 50c ecofee for a litre of paint has proved to be too little a fee to encourage consumers to change their consumption habits. A s a result, it is unlikely that the paint industry w i l l experience decreases in paint sales. A n d for this reason, the industry is in my opinion, keen to keep the ecofee at the very low level at which consumers w i l l not 'mind' paying an ecofee while continuing to buy a lot more paint than they consume.  52  2. The volume o f paint collected annually has increased from slightly more than 1,300,000  equivalent  litre  containers  in  1995 to  nearly  3,000,000  in  1997.  Considering the amount of paint sold annually has not been revealed and there is no data regarding how much residual paint was dumped before and since the program has been in place, these volumes o f paint brought to the depots do not reveal much about the program. It is possible that less paint is being dumped now than before but is also possible i f sales have gone up that more paint is being dumped now than before. These possibilities stemming from the absence o f vital data means that I cannot conclude one way or the other about whether the program is achieving the objectives o f product stewardship. 3. O f the residual paint that was collected in 1997, 51% was recycled into building materials, 30% involved in energy recovery, 11% was treated and landfilled, while 8% was reused. Given these findings, I concluded that the objective o f minimizing as much as possible the volume o f paint disposed of in landfills would best be attained by preventing the occurrence of residuals to begin with. 4. Other outcomes of the program included employment creation, big companies doing business with local level small business such as Joe's Bottle Depot. A s well, paint is now available free o f charge to the public via a paint exchange program. O n the question o f whether the product stewardship concept is a feasible solution to hazardous post consumer products, I argued that while an opportunity has been created for a sound hazardous waste management practice, the program has so far not reached its full potential largely because the program is not being operated in a way that best  53  encourages the highest achievements. But nonetheless, a step has been taken. A system is in place for managing paint waste, what is now needed is to improve the workings o f the program in order to tap into the benefits that product stewardship offers. On a concluding note, I would like to reinforce two major points: First, the product stewardship concept applied to hazardous products appears to me to be a feasible approach to waste management of post consumer products requiring special disposal. It has been proven that when industries pay environmental costs of disposal they have reformulated their products to make them more suitable for general disposal. The ecofee has so far not proved to be as effective a strategy for changing consumer practices as I anticipated maybe because a 50c ecofee per litre of paint is too small a fee to compel consumers to change their practices. Maybe i f the fee were higher and a rebate were given (about 1/2 back) when the empty cans are returned, the fee would work better. A s well, the process o f change occurs gradually. Maybe a little more time must elapse before the paint program can positively change consumer habits. Secondly when well implemented product stewardship initiatives present an opportunity to bridge the gap between the economy and the natural system. The activities pursued by the paint program, for example, potentially lead to improved environmental protection. Reusing and recycling for instance, potentially reduce the volume of material that has to be extracted from the natural system as raw materials for new products. Reusing reduces the volume of waste that is deposited into the environment and this has two positive impacts: one is that environmental pollution is minimized and second, the assimilative capacity is not as quickly used up.  54  Although the body o f evidence on the effectiveness o f product stewardship initiatives in B C is still limited because of major data gaps, experience in some European countries especially Germany is beginning to show that product stewardships can be an effective and efficient means o f improving environmental protection and enhancing economic efficiency by reducing distortions in the economy. I am optimistic that the shortfalls and challenges I observed about the paint program in B C w i l l gradually be corrected and more concrete results w i l l come out of the program. Given the urgency i n need for solutions to the stifling problems o f waste management, I am convinced that the concept of product stewardship in general and B C ' s paint program in particular w i l l be replicated in other provinces which are currently grappling with the problems and issues associated with post consumer wastes.  55  Works Cited Ackerman, Frank. 1997. Why Do We Recycle? Markets, Values and Public Island Press, Washington, D C .  Policy.  Alexander, Judd., 1993. In Defense of Garbage. Praeger: Connecticut. B C Environment., 1993. Household Hazardous Waste Strategy. Discussion Paper. Toxics Reduction Branch, Ministry of Environment, Lands and Parks. Bulleid, Peter., 1993. The Environment And The Planning System: Business Implications in Business And The Environment Practitioner Series. Technical Communications Publishing: Oxford. Business Adapts to a New Environment British Columbia: Vancouver  Reiterate. October 1996.. Recycling Council o f  Chen, Huey-Tsyh., 1990. Theory Driven Evaluations. Collier, John., 1995. The Corporate Environment.  Sage Publications: London.  Pr entice Hall: Toronto  Contaminated Sites Management in the Province of British Columbia., February 1990. A Review of Provincial Roles And Responsibilities. Ministry o f Environment B . C Costanza, Robert., Olman Segura and Juan Martinez-Alier (ed.)., 1996. Getting Down to Earth. Practical Applications of Ecological Economics. Island Press: Washington, DC Costanza, Robert; Charles Perrings and Cutler Cleveland (ed.)., 1997. The Development of Ecological Economics. Edward Elgar Publishing: Vermont, U S A Derek Stevenson., 1998. Solid Waste & Recycling. Extended Producer Responsibility. A L o o k at Costs in Europe. Dillaway, Diana. 1992. Capturing the Local Economic Benefit Of Recycling. A Strategy Manual for Local Governments. A Publication of Local Government Commission. Sacramento: California. D w i v e d i , O.P., 1997. India's Environment Martin's Press: N e w York.  Policies, Programs and Stewardship.  St.  Epstein, M a r c , 1996. Measuring Corporate Environmental Performance. Best Practices for Costing and Managing an Effective Environmental Strategy. Irwin: London.  56  Facing America's Trash. What Next for Municipal Solid Waste? Congress o f the United States. Office of Technology Assessment. U S Government Printing Office: Washington, D C . Fishbein, Bette. 1994. Germany, Garbage, and the Green Dot. Challenging the Throwaway Society. I N F O R M : U S A . Forester, W i l l i a m and John H . Skinner (ed.). 1992. Waste Minimization and Clean Technology: Waste Management Strategies for the Future. Academic Press: Toronto. Gandy, Matthew., 1994. Recycling and the Politics of Urban Waste. St. Martin's Press. N e w York. Get Industry to Clean Up After Itself. Reiterate. M a y 1994. The Newsletter o f the Recycling Council o f British Columbia: Vancouver Goldin, Ian and A l a n Winters (ed.)., 1995. The Economics of Sustainable Cambridge University Press: Cambridge  Development.  Greener Homes, Cleaner Communities., 1994. Report on a Provincial Strategy to Reduce and Manage Household hazardous Waste and Products. Waste Reduction Commission: Soils A n d Hazardous Waste: Vancouver, B C . Jacobson, Joel and Jerry F. English. 1980. Recycling in the 1980s. The Report on Recycling in New Jersey by the State Advisory Committee on Recycling. State o f N e w Jersey Office o f Recycling. Kharbanda, O.P. and E . A . Stallworthy., 1990. Waste Management. Sustainable Society. Urban House: N e w York.  Towards A  Lower Mainland Refuse Project. 1984. Concepts Report. A Report on a Variety of Options For Solid Waste Management In The Lower Mainland of British Columbia: Surrey, British Columbia. Mohr, Lawrence., 1995. Impact Analysis for Program Evaluation 2. Sage Publications: London Moos, Frank., Feb./ March 1998. Waste, Wasteful Talk, and Conservation (in Extended Producer Responsibility: A Look at Costs in Europe). Solid Waste and Recycling: Canada's Magazine on Collection, Hauling, Processing and Disposal. National Research Council., 1995. Improving the Environment. An Evaluation of DOE's Environmental Management Program. National Academy Press: Washington, DC 57  O E C D . , 1997. Sustainable Development. OECD Policy Approaches for the 21st Century. O E C D : Paris. Product Durability and Product Life Extension. Organization for Economic C o operation and Development. 1982La Duree De V i e Des Produits: Paris. Ortolano, Leonard., 1997. Environmental Wiley: N e w York.  Regulation And Impact Assessment. John  Paint Is a Resource, Not a Waste Post Consumer Paint Management: A n N P C A Issue Backgrounder, A p r i l 1995. N P C A Home Page: http://www.paint.org/apr95.htm Patton, Michael., 1990. Qualitative Evaluation and Research Methods. Second Edition. Sage Publications: London. Perrings, Charles., 1987. Economy and Environment. A Theoretical Essay on the Interdependence of Economic and Environmental Systems. Cambridge University Press: Cambridge. Perrings, Charles., 1997. Economics of Ecological Resources. Edward Elgar: L y m e , U S A Piasecki, Bruce., 1995. Corporate Environmental Toronto.  Strategy. John Wiley and Sons:  Post-Consumer Paint Stewardship Program Regulation. The Ministry o f Environment, Lands and National Parks, http://www.qp.gov.bc.ca/stat_reg/regs/elp/r200_94.htm Powelson, David., Melinda Powelson., 1992. The Recycler's Manual For Business, Government, And The Environmental Community. V a n Nostrand Reinhold: N e w York. Product Stewardship Model in Recycling Product News.. M a y 1998.. V o l . 6 Baum Publications L t d . : Vancouver.  No. 4  Rees, W i l l i a m . , 1989. Defining Sustainable Development. U B C Center for Human Settlements: Vancouver. Rees, W i l l i a m . , 1991. Conserving Natural Capital: The Key to Sustainable Landscapes. University of British Columbia: Vancouver (main reserve- plan 505) Rennie, Caroline and Alair MacLean., 1989. Salvaging the Future: Waste Based Production. Washington, D C : Institute for Local Self Help.  58  Reynolds, Peter (ed.). 1974. Symposium On waste Recycling And the Environment. Royal Society o f Canada. Ottawa. Rogers, Michael (ed.)., 1995). Business and The Environment. York  The  St. Martin's Press: N e w  Old Paint Begins to Flow Back To It's maker in B. C, February, 1996. Reiterate Recycling Council of British Columbia: Vancouver  The  Reverse Logistics Management Reiterate. October 1996. The Recycling Council o f British Columbia: Vancouver The Paint Industry's Environmental Stewardship Efforts., June 1997. N P C A Issue Backgrounder, http://www.paint.org/jun96.htm Washington State Department o f Ecology., January 1992. Washington State Hazardous Waste Plan. Publication # 92-05. Olympia: Washington Whicker, Marcia., 1993. Controversial Issues in Economic Regulatory Policy. Sage Publications: London. White Elephant Round Up! Reiterate. November 1993. The Newsletter of the Recycling Council o f B C : Vancouver Williams, Douglas., 1997. Performance Measurement: What It Is and What it Can Do for You. The A R A Consulting Group (unpublished): Vancouver. Whole'y, Joseph (ed) ., 1987. Organizational Excellence: Stimulating Quality and Communicating  Value. Lexington Mass: Lexington Books.  59  APPENDIX 1 Hierarchy of options within waste management 1) waste reduction: process.  waste minimization and waste prevention in the production  Waste reduction can either refer to a reduction in the toxicity of waste or to a  reduction in the quantity of waste produced .  2) reuse: where the production of wastes is unavoidable within the production itself. This is easier than post consumer recycling, since uncontaminated  process  and  economically handleable quantities of wastes are in proximity to industry as potential new raw materials. Some items sold are made in such a way, and contain no post consumer waste, whereas in other cases there may be a mixture of pre and post consumer wastes which have bee recycled.  3) product reuse and repair of products to prolong their usefulness before entering the waste stream. There is debate over the tradeoff in overall objectives between energy saving in their cleaning and transportation in comparison with the manufacture of new. containers.  4) primary reclamation of materials to create new raw materials. Methods of reclamation include: 'collector curbside schemes'; bring systems ; centralized  sorting  plants.  5) Secondary Recovery of energy from the caloric value of materials. incineration  Includes  and production of refuse derived fuel.  * (Duplicated from Gandy 1993:45 but is similar to the hierarchies adopted by several other authors and  institutions).  60  P H S T - C O N S U M E R PAINT S T E W A R D S H I P P R O G R A M R E G U L A T I O N  '  littpt/Avww.qp.gov.bc.ca/stnljen/rces/clp^OO 9-1  U  I  Copyright © 1998: Queen's Printer, Victoria, British Columbia, Canada  This is not the official version.  Only the printed version issued by the Queen's Printer is the official version. Copies of the official version may bo obtained from Crown Publications Inc., 521 Fort Street, Victoria, B.C. V 8 W 1E7, telephone: (250) 386-4636, or from the Queen's Printer office located at 849 Hornby Street, Vancouver. %  Copyright in the electronic version of the Post-Consumer Paint Stewardship Program Regulation belongs exclusively to the Province of British Columbia. This electronic version is for private study or research purposes only.  m  No person or entity is permitted to reproduce this regulation in whole or in part for distribution either free of charge or for "commercial purposes," unless that person or entity has a signed licence agreement with the Queen's Printer for British Columbia. Reproduction for commercial purposes is reproduction for the purposes of sale, rent, trade, or distribution, or posting it on the Internet or on eic-Lronic bulletin boards. Further details about copyright protection over these and other government-owned works can be obtained by reference to the federal Copyright Act.  in id !  B . C . Reg. 200/94  Deposited June 23, 1994  O . C . 830/94  -  Waste Management Act  1  effective September 1. 1994  POST-CONSUMER PAINT STEWARDSHIP PROGRAM REGULATION [includes amendments up to B.C. Reg. 218/97]  1  Contents 1 Interpretation  i  . ."  2 Application of this regulation  3  Duties of brand-owner  ,.-,.4  "4 Approval of stewardship program 5 Report to the director 6 Requirement to provide educational and consumer information 7 Requirement of seller to post a sign .8 H SB  Requirements of the stewardship program ••..'  9 Confidentiality  ...... -.. ' ' a ' ; ;  10 Offence and penalty 11 Repealed  Interpretation  1 In this regulation: -J  "brand-owner" means (a) a person in British Columbia who is the owner or licensee o f a trade mark under which a consumer paint product is sold or otherwise distributed in British Columbia, whether the trade mark is registered or not, (b) a person who brings into British Columbia a consumer paint product for sale or other distribution in British Columbia, or  a• 03/17/98 16:06  T - C O N S U M E R PAINT S T E W A R D S H I P P R O G R A M R E G U L A T I O N  http://w\v\v.qp.»ov.bc.ca/s(at_rcg/icgs/elp/r200 94.htm  (c) an association representing one or more o f the persons referred to in paragraph (a) or (b);  "consumer paint product" means (a) latex, o i l and solvent based architectural coatings, including stains and paints for commercial and homeowner use, whether tinted or untinted, and (b) paints and stains, whether coloured or clear, sold in pressurized aerosol containers, but does not include unpressurized coatings formulated for industrial, automotive or marine anti-fouling applications; "point of display" means an area o f a seller's premises where consumer paint products are displayed; "point of sale" means an area o f a seller's premises where the transaction to purchase a consumer paint product takes place; "post-consumer paint" means a consumer paint product and its container that is no longer wanted by the consumer for its original purpose; "return collection facility" means a place for the return and short term storage or treatment o f post-consumer paint; "rural area" means an area that is not an urban area; "seller" means a person who, as a wholesaler, distributor or retailer, sells or offers for sale consumer paint products including, without limitation, a bulk paint distributor, department store, grocery store, hardware supply store or drug store or any other person who sells or offers for sale consumer paint products; . • "short term storage" means storage for a period o f time not exceeding 6 months; "stewardship program" means a program that (a) provides for the collection, transportation and final treatment o f post- consumer paint regardless o f the original brand-owner or seller o f that consumer paint product, (b) incorporates the principles o f pollution prevention through the implementation o f the pollution prevention hierarchy by moving progressively from treatment or containment to recovery o f energy, recycling or reuse, and (c) complies with sections 6 (1) and 8; "urban area" means a municipality that has a population greater than 25 000. [am. B . C . Regs. 506/94, s. 1; 101/96, s. 1; 218/97, s. (a).]  Application of this regulation  2 This regulation applies to every brand-owner and seller of consumer paint products in British Columbia.  62  8  03/17/98 16:06:44  ^ S T - C O N S U M E R PAINT STEWARDSHIP P R O G R A M R E G U L A T I O N  hltp:/Avww.qp.gov.bc.ca/si;il_rcg/regs/elp/r200 94.hi in  L' Duties of brand-owner 3 (1) A brand-owner must not sell, offer for sale or otherwise distribute, either directly or indirectly, a consumer paint product in British Columbia unless (a) the brand-owner operates an approved stewardship program, or (b) the brand-owner contracts with a person for the purpose o f operating an approved stewardship program. (2) A brand-owner, or the person operating an approved stewardship program on behalf o f the brand-owner, must treat, contain, recover energy from, recycle or reuse all post-consumer paint within 6 months after collecting or receiving the post-consumer paint at the return collection facility. [am. B.C. Reg. 506/94, s. 2.]  Approval of stewardship program \ •i 4 ( 1 ) For the purposes o f section 3 (1). a brand-owner must submit a stewardship program to the director for review and approval.  p-i  (2) The director may fj  (a) approve the stewardship program, (b) reject the stewardship program, or  [|j  , •,.  (c) return thestewardship program to the brand-owner for further information, v  ••. .•••<..«•'?'•'•• \  (3) The director must provide the brand-owner with reasons i f a stewardship program is rejected under subsection (2) (b).  ,3 [am. B . C . Reg. 506/94, s. 3.]  li  1  Report to the director 5 ( 1 ) Every brand-owner must, on or before March 31 i n each year, provide to the director an annual report detailing the effectiveness o f the brand-owner's stewardship program during the previous calendar year including, but not limited to, the following:  p)  ,  (a))the total amount o f consumer paint products sold and post-consumer paint collected; L  (b) the total amount o f post-consumer paint processed or i n storage;  I.: y  (c) the percentage o f posfconsumer paint that was treated or contained, utilized for recovery o f energy, recycled or reused, including efforts taken through marketing strategies or product and packaging reformulation o f consumer paint products to reduce post-consumer paint and packaging waste;  ess  (d) a description o f the types o f processes utilized to treat or contain, recover energy from, i ! I i'8  53 .  03/17/98 16:06:44  -fppT-CONSUMER PAINT S T E W A R D S H I P P R O G R A M R E G U L A T I O N  http://www.qp.gov.bc.ca/slal rc»/rcgs/elp/r200 94.hlm  |j  p | J  '  (d) a description o f the types o f processes utilized to treat or contain, recover energy from, recycle or reuse post-consumer paint, including details o f efforts to move up the pollution prevention hierarchy from treatment or containment to reuse; (e) the location o f return collection facilities:  0 1  (f) the location o f any long term containment or final treatment and processing facilities for ; post-consumer paint; (g) the types o f consumer information, educational materials and strategies adopted under the educational and informational program o f the brand- owner's stewardship program; (h) the annual financial statements, as prepared by an independent audit, o f the revenues received and the expenditures incurred by the brand-owner's stewardship program; (i) the process o f internal accountability used to monitor the environmental effectiveness o f the program. (2) O n receipt o f the report under subsection (1), the director may require that a brand-owner (a) make amendments to the brand-owner's stewardship program as approved under section 4, or (b) submit a new stewardship program to the director for review and approval.  f ~] i I  r  (3) B y A p r i l 30, July 31, October 31 and January 31 o f each year every brand-owner must provide the director with information on the total post-consumer paint collected during the previous calendar quarter. [am. B.C. Regs. 506/94, s. 4; 101/96, s. 2.]  Requirement to provide educational and consumer information  6 ( 1 ) Every brand-owner must provide, free o f charge to each seller o f its consumer paint products, educational and consumer information respecting that brand- owner's consumer paint products sold from the seller's premises, which information informs consumers about the following: '• ' (a) on and after January 1, 1995, the brand-owner's approved stewardship program; (b) access to return collection facilities; ^|  r, ij  (c) the environmental and economic benefits o f participating i n the stewardship program. (2) Every seller must provide, either at the point o f display or point o f sale o f the consumer paint products, a place for the display o f the information supplied by the brand-owner under subsection (1). (3) The display o f information must be clearly visible and the information must be made available free o f charge in printed form in quantities sufficient that a consumer may remove a copy o f the information from the premises. (4) A brand-owner o f a return collection facility that commenced post-consumer paint collection on or after A p r i l 1, 1996 must notify, within one year o f commencing collection, the consumers to be served by the return collection facility as to the location and operating hours o f that return 64  03/17/98 16:06:44  >ST-CONSUMER PAINT STEWARDSHIP P R O G R A M R E G U L A T I O N  http:/Avvvw.qp.gov.bc.ca/slaljeg/regs/elp/r200_9-;.liim  j  be served by (lie return collection facility as to the location and operating hours o f that return collection facility. (5) The notification under subsection (4) must (a) be by advertisement, that is approved as to size and content by the director, in a newspaper serving the affected communities, and (b) be based on the following schedule: (i) one advertisement per week for 4 consecutive weeks; (ii) thereafter one advertisement bi-weekly during the next 48 weeks. (6) A brand-owner o f a return collection facility that commenced post-consumer paint collection before A p r i l 1, 1996 must notify, before December 31,1996, consumers to be served by the return collection facility as to the location and operating hours o f return collection facilities in the community. (7) The notification under subsection (6) must (a) be by advertisement that is approved as to size and content by the director, in a newspaper serving the affected communities, and (b) be based on the following schedule: |  (i) one advertisement per week for 4 consecutive weeks; (ii) thereafter one advertisement bi-weekly during the next 20 weeks..  1  (8) In addition to the other notifications required under this section, a brand-owner o f a return collection facility must notify the public through a series o f radio advertisements,, the content and schedule o f which must be approved by the director. 1  3  [am. B.C. Regs. 506/94, s. 5; 101/96, s. 3.]  . y , - ^ ^ ^ ^ . , ^ ^ ^ ^ . .  Requirement of seller to post a sign SIS  7 Every seller must post at the entrance to the seller's premises, the point o f display or the point o f sale at least one clearly visible sign with m i n i m u m dimensions o f 56 c m by 43 c m and a minimum print font size o f 24 points that is i n a contrasting colour to the background colour o f the sign and that provides information to the consumer respecting the location and hours o f operation o f the return collection facility that w i l l accept a brand-owner's post-consumer paint. . [en. B.C. Regs. 506/94, s. 6; 101/96, s. 4.]  Requirements of the stewardship program  8 ( 1 ) Every brand-owner must, as a component o f its stewardship program, do one o f the following: (a) provide, af the premises o f each seller who sells the brand-owner's consumer paint products, a return collection facility; 65  03'17/98 16:06:45  f i V r - C O N S U M E R PAINT S T E W A R D S H I P P R O G R A M R E G U L A T I O N  Iutp://www,qp.gov.bc.ca/slat_rcg/regs/elp/r20() 94.him  (1 li  (b) provide, at a location other than the premises o f each seller who sells the brand-owner's consumer paint products, a return collection facility;  n j|  (c) contract, with a person who operates a return collection facility, for the use o f that facility by a seller who sells the brand-owner's consumer paint products. (2) The return collection facility described in subsection (1) (b) or (c) must be located (a) not more than 4 kilometres by road from the seller's premises i f the seller's premises are located in an urban area, or  \  \  (b) not more than 10 kilometres by road from the seller's premises i f the seller's premises are located in a rural area.  j-  | i o  (3) Despite subsection (2), the director may, on application to the director by the brand-owner or an agent o f the brand-owner, waive the location requirements o f that subsection to permit the use o f a return collection facility that is located more than 4 kilometres by road from the seller's premises in an urban area or more than 10 kilometres by road from the seller's premises in a rural area.  ?:0  ( 4 ) The director may consider the following when granting a waiver under subsection (3):  1  (a) the population o f the market served by the seller; f]  (b) the accessibility and location o f the closest possible alternative return collection facility to the seller's premises;  e  (c) the number o f brand-owners' who have, for the purposes o f this regulation, contracted with the closest return collection facility; . :  .,,. ... v  (d) the number and location o f other return collection facilities within a 10 kilometre radius v o f the seller's premises i n an urban area or within a 20 kilometre radius o f the seller's & premises in a rural area; ;•. \^ .. . . • ' '•. ;  (e) the number o f waivers already granted to brand-owners within a 10 kilometre radius o f the seller's premises in an urban area or within a 20 kilometre radius o f the seller's premises in a rural area; < l|  (f) any other factor that, i n the opinion o f the director, is relevant.  p|  (4.1) A waiver granted under subsection (3) may be made in respect o f one or more sellers o f a brand-owner's consumer paint products. ^ -  fSj  (4.2) A brand-owner must provide and maintain each return collection facility listed i n a waiver under subsection (3).  (5) Repealed. [B.C. n  Reg. 218/97, s. (b).]  (5.1) A return facility must (a) be available, without charge, to any consumer who wishes to return post- consumer paint and containers, whether empty or not, regardless o f the original brand-owner or seller o f the consumer paint, and (b) operate, and be available to the public, during regular business hours 5 days a week, one day o f which must be Saturday.  66  03/17/98 16:06:45  •ftST-CONSUMER PAINT STEWARDSHIP P R O G R A M R E G U L A T I O N  | ] t-'  • hltp:/Av\vw.qp.gov.bc.ca/sfat_rcu/rcs;s/clp/r2()() 9.-1.htm  (6) Despite subsection (5), the director may, on application to the director by the brand-owner or an agent o f the brand-owner, waive the requirement for minimum hours and days o f operation to permit the operation o f a return collection facility during hours and days specified by the director. (7) The director may consider the following when granting a waiver under subsection (6): (a) the geographical area that the return collection facility serves; (b) the population o f the geographical area; (c) the total amount o f post-consumer paint previously received by the return collection facility; (d) any other factor that, in the opinion o f the director, is relevant. (8) A waiver granted under subsection (6) may be made in respect o f one or more return collection facilities operating under a stewardship program. (9) Return collection facilities in operation on or after A p r i l 1, 1996 may not discontinue collecting post-consumer paint unless an alternative return collection facility is approved by the director. . (10) A brand-owner's stewardship program must, before January 1, 1998, ensure that 70% o f the reusable and recyclable portion o f the post-consumer paint collected during the previous year is reused or recycled. (11) Brand-owners must submit to the director, on or before March 31, 1997, a testing procedure protocol that w i l l determine the portion o f post-consumer paint collected that is reusable and recyclable.  .| ] 1:5  § 5 ( 1 2 ) The director may either approve,''amend'''or reject the protocol submitted uiider subsection (11) and set the amount o f post-consumer paint that the director considers is reusable and 1  .,.; :..^ ,.recy^lable. iss?  ;  v  .  1  .......^.^^i^^-^,.,,^;.^  [am. B . C . Regs. 506/94, s. 7; 101/96, s. 5; 218/97, s. (b).]  Confidentiality  bJ  9 ( 1 ) Every person acting under the authority o f this regulation must keep confidential all facts. information and records obtained or furnished under this regulation, except so far as public duty requires or this regulation permits the person to make disclosure o f them or to report or take official action on them. (2) The director may disclose the information regarding the effectiveness o f a brand- owner's stewardship program provided in the annual report required under section 5. (3) O n application from the brand-owner, the director may withhold from the disclosure under subsection (2) sales and financial information that the director considers w i l l place the brand-owner at a competitive disadvantage. [am. B.C. Reg. 101/96, s. 6.]  m  67  03/17/98 16:06:4  S T - C O N S U M E R PAINT S T E W A R D S H I P P R O G R A M R E G U L A T I O N  IUlp:/Av\v\\\qp.gov.lK.ca/st;il_reg/regs/clp/r200_ )4.hiin t  Offence and penalty  10 (1) A person who contravenes section 3, 5 (1) or (3), 6, 7 or 8 (1), (2), (4.2), (5), (9), (10) or (11) commits an offence and is liable on conviction to a fine not exceeding $200 000. (2) A person who is convicted o f an offence under subsection (1), for contraventions o f section 3, 5 (1), 6 (1) or 8 (1), (2), (4.2), (5) or (9), must stop selling, distributing or otherwise offering for sale consumer paint products in British Columbia until the contravention is remedied to the satisfaction o f the director. [am. B.C. Regs. 506/94, s. 8; 101/96, s. 7.]  11 Repealed. [B.C. Reg. 101/96, s. 8.]  [Provisions o f the Waste Management Act, R . S . B . C . 1996, c. 482, relevant to the enactment o f this regulation: section 57]  Link to O o O O  the Home Page for: Ministry of Environment. Lands and Parks Government of British Columbia Legislative Assembly of British Columbia Queen's Printer  Copyright© 1998: Queen's Printer, Victoria, British Columbia, Canada  68 03/17/98 16:06:45  Appendix 4: Consumer Questionnaire I am a Master's student in the School of Community and Regional Planning at the University of British Columbia. I am doing a study to determine the outcomes of the Post Consumer Paint Program in B C As part of the study, I am interested in knowing consumers consumption habits as well as their perspectives on a few topics. The information that I obtain will be incorporated into my thesis on Product Stewardship Initiatives: The Case of Post Consumer Paint. I will not request any personal information from you and if you are not comfortable or willing to participate -feel free to not participate. It will take less than five minutes to complete the survey and I will ask the questions and write down your responses. Recycled products can have several environmental benefits including e.g. prolonging product life and possibly reducing raw material consumption; 1. Would you consider purchasing recycled paint? YES NO REASON  2. If the price of recycled paint were less than the current rate of conventional paint, would you consider purchasing recycled paint? 3. A r e you aware of the post consumer paint stewardship program? Yes No 4. Where do you dispose of unwanted or left over paint (a) down the drain  (b) In the trash  (c) paint depot  (d) keep it in the home indefinitely for eventual use  (e) Other  5. Do you agree with the concept of an ecofee to fund a program for the safe disposal of paint? Yes  No  Why?  6. Does the ecofee deter you from purchasing more paint than you need? Yes No  7. Have your consumption habits been affected in any way by the educational brochure detailing the need to protect the environment from pollution by chemicals such as the ones in paint?  70  Appendix 4 a: Summary of Results The survey was carried out in M a y 1998 (over ,a one week period) at 3 different paint stores, A b o u t 70 potential respodents (household paint consumers) were approached. 50 consumers agreed to respond to the survey. 1 asked questions and wrote down responses.  Summary of the survey results 1. Would you consider purchasing recycled paint?  Yes 13% •  8% for certain jobs e.g. graffiti  t  7% if recycled paint were cheaper  No 48% 2. Are you aware of the paint stewardship program?  Yes  3. Where do you dispose of unwanted paint?  90%  No 10%  a) down the drain 1%  b) in the trash 11%  c) paint depot 56%  d) store paint indefinitely 30%  e) other 4. Do you agree with the concept of an ecofee to fund a  Unsure 39%  Yes  2%  85%  No 15%  program for the safe disposal of paint? 5. Does the ecofee deter you from purchasing more paint  Yes 21%  No 77%  2% did not know  than you require for a specific job? 6. Is the ecofee an incentive for you to bring residuals to a  Yes 54%  depot for processing?  No 46%  ^ 30% would bring residuals regardless —•  16% were not sure if the ecofee is a factor  in such a decision  7. Has the consumer educational program affected  Yes  your cosnumption habits?  No  27% 65%  8% were not aware of the consumer educational brochure and program  71  

Cite

Citation Scheme:

        

Citations by CSL (citeproc-js)

Usage Statistics

Share

Embed

Customize your widget with the following options, then copy and paste the code below into the HTML of your page to embed this item in your website.
                        
                            <div id="ubcOpenCollectionsWidgetDisplay">
                            <script id="ubcOpenCollectionsWidget"
                            src="{[{embed.src}]}"
                            data-item="{[{embed.item}]}"
                            data-collection="{[{embed.collection}]}"
                            data-metadata="{[{embed.showMetadata}]}"
                            data-width="{[{embed.width}]}"
                            async >
                            </script>
                            </div>
                        
                    
IIIF logo Our image viewer uses the IIIF 2.0 standard. To load this item in other compatible viewers, use this url:
http://iiif.library.ubc.ca/presentation/dsp.831.1-0088654/manifest

Comment

Related Items