Niagara Region Comments on…

Niagara Region Comments on Proposed Food and Organic Waste Framework
Niagara Region supports the implementation of the proposed Food and Organic Waste Framework as an important step in reducing the amount of food and organic waste being generated and disposed of in Ontario, and is pleased to note the incorporation of a number of items, previously submitted as comments in response to the Province’s “Discussion Paper: Addressing Food and Organic Waste in Ontario” (Discussion Paper).
Comments and concerns on the Framework, which were formulated by Public Works, and Public Health and Emergency Services Departments, are included below.
Part A - Waste Management Services, Public Works Comments
Previous Niagara Region Comments Addressed:
The following components of the Framework reflect some of the key concerns identified in the Niagara Region’s response to the Discussion Paper.
•The expanded vision to take a systems approach to food and organic waste generation, management and recovery, recognizing that all stages of supply and production have a role to play in moving towards a circular economy (Page 8) is positive. Niagara Region’s position to date, reflected in the Framework, has been that actions focusing on prevention of food and organic waste are critical in attaining goals to minimize the amount of food and organic waste to be disposed of.
•Food and organics are a costly stream for municipalities to collect and process and alternatives that have greater social, economic and environmental benefits are offered in the Framework, specifically including reduced waste generation (e.g. safe distribution of surplus food).
•The Province appears to be making allowances for different technologies and capabilities of processors, for example, by defining materials that are required to be included in waste reduction and recovery resources, versus additional materials the Province encourages municipalities to include, both of which can also be applied toward meeting targets (Page 41). The Province also commits to actions supporting development of resource recovery infrastructure and supporting markets for biogas. The challenge will be the development of additional capacity and end markets.
•The creation of data collection mechanisms for measuring progress in waste reduction and resource recovery is vital and Niagara Region is pleased to see separate targets and development of measures for the low density residential dwellings (i.e. single family), institutional, commercial and industrial (IC&I) and multi-unit residential sectors. The application of the targets, etc. will need to consider that some municipalities, such as Niagara Region, offer food and organics collection (excluding leaf and yard material) to multi-unit residential properties and the small to medium-sized IC&I properties.
Previous Niagara Region Comments Not Addressed:
•Niagara Region had previously flagged the challenges that municipalities face with respect to compostable packaging, namely that the material does not all break down in the various organic processing systems, at the same rate, and/or the material is incorrectly placed in the Blue Box program. Some producers may move toward compostable packaging to avoid producer responsibility for designated paper and packaging. This proposed Framework includes a policy section on Compostable Products and Packaging. The Province does not identify specific criteria or standards but does note on page 50 that “As compostable products and packaging become more common in Ontario there is broad recognition that more work needs to be done to better integrate these new types of packaging into Ontario’s circular economy”. The policy statement encourages (but does not mandate) the following:
5.1 Persons or entities that are brand holders of or market compostable products and packaging should ensure they are certified according to international, national or industry standards and meet environmental standards in Ontario.
5.2 Municipalities and owners and operators of resource recovery systems that process food and organic waste are encouraged to support new technology and innovation to recover compostable products and packaging.
5.3 Persons or entities that are brand holders of, or market compostable products and packaging should provide promotion and education to inform consumers on how to participate in resource recovery programs for compostable products and packaging.
The Province should take a firmer stance, for example, designating all packaging. Producers need to take responsibility for branded (i.e. non-food) organics. The guidelines to be developed in spring 2018 that will support the Framework should reflect this, along with future regulations.
Although brand holders are required to provide P&E and ensure packaging is acceptable for municipal organics processing systems, there are variations between municipal processing systems (e.g. some programs accept diapers), which may make Province-wide P&E messaging problematic and may contribute to resident confusion.
•Niagara Region had previously flagged that public spaces and community events (e.g. festivals) generate food and organic waste. Although Action 11 “Province to develop best management practices to support effective use of public waste receptacles” (Page 18) takes a step toward addressing this, there are no specific targets or stakeholders specifically designated against this source of material. The guidelines should be expanded to include programs such as food and organic collection at special events, already existing in some municipalities, including Niagara Region.
•Niagara Region had previously identified that a key component of increasing diversion rates in Ontario is to engage the IC&I sector. The Framework identifies multi-unit residential buildings in Southern Ontario, and IC&I facilities, sectors for which Niagara Region currently services a subset of properties, as stakeholders with specific timeframes and targets for reduction and resource recovery (page 40). Niagara Region and other municipalities that service these sectors are impacted and should provide input into the development of baseline and ongoing measures for these sectors. Stakeholders, need a clear understanding of reporting requirements and funding opportunities, which appear to be limited at this time.
•Niagara Region is supportive of a disposal ban, as noted in our comments on the “Discussion Paper: Addressing Food and Organic Waste in Ontario”. The Province should consider, however, that there is potential for additional administrative costs to municipalities. This was reiterated in the Province’s presentation regarding the Framework on December 1, 2017, when the Province confirmed that municipalities are responsible for enforcement through by-laws. In addition, increased time between implementation of the disposal ban and the target date for the 70 per cent waste reduction and resource recovery of food and organic waste, would allow for the beneficial impact of the ban to be experienced.
Based on the proposed content in the Framework, an additional implementation concern is that Niagara Region collects waste from low density residential dwellings, smaller multi-unit residential buildings, and small to medium-sized IC&I properties, as part of the residential collection route. This may make thresholds for compliance and Regional enforcement more challenging considering separate targets, etc. for the multi-unit residential buildings and the IC&I sector.
•The Province has committed only to limited funding with rigorous requirements for accessibility and applicable only for certain projects (e.g. related to GHG, with a start date after June 2016, etc). There is no on-going, annual funding available. Municipalities must be fairly compensated for any additional costs related to disposal bans or for any new major costs, as a result of this Framework.
Areas of Concern Which Require Additional Details:
Although future guidance documents and regulation will provide more details, there are a number of issues, which have yet to be addressed and are of importance to Niagara Region:
•The Framework states that municipalities have a residential resource recovery rate of approximately 50% but it is not clear how this percentage was determined. The parameters to be used (e.g. P&E credits for waste reduction) and the detailed calculation to establish a baseline and future measurement for the percentage of waste reduction and resource recovery of food and organic waste for low density residential dwellings needs to be defined. This is important for budgeting purposes (i.e. does Niagara Region need to increase the tonnage of food and organic waste captured in order to meet the 70% reduction and recovery target or will other initiatives allow us to achieve the target with no further effort in the curbside collection program). This is also critical to estimating how much capacity is available in Niagara’s existing processing contract.
•The Ministry needs to ensure that the calculation used to determine the percentage of waste reduction and recovery considers the on-site management of organics through grasscycling and backyard composters and ensure that blended targets do not remove the incentive/benefit for municipalities to continue to maximize these activities.
•More details and refined timelines are needed for the actions, regulations and most importantly creation of additional processing capacity and stimulating end markets. Given that more investigation and study is occurring by the Province, and there is concern regarding capacity and end markets, the timelines that impact municipalities will likely need to shift. However, planning for additional capacity in order to accommodate more tonnages captured through the food and organic waste collection program is more immediately critical for municipalities such as Niagara Region, who have a tonnage threshold at which the processing costs increase or cases where there is little or no excess capacity. More detail on the calculation for baseline and future measurement of targets (as noted above) will greatly inform Niagara Region’s medium term planning process.
Part B - Public Health Comments
Specific concerns and considerations from Niagara Region’s Public Health perspective are identified below:
Nutrition Specific Components
•Health interests (food safety, nutrition promotion, food security) should be incorporated more into the Framework report:
1.Recommendation (pg. 8)
-Consider adding the following bullet to the “Key guiding principles” section: “Enabling the capability and sustainability of the food system to provide food to promote health for all Ontarians”.
2.Recommendation (pg. 12, paragraph 3)
-The Province should add healthy eating promotion expertise amongst the listed priority partners “…to develop educational tools and resources, which could be tailored for various audiences”.
-Healthy eating promotion expertise in food literacy includes elements consistent with the given examples. This includes the areas of promotion, education and guidance materials, meal planning and food storage, how to extend the life of food and opportunities for imperfect produce.
•Prevention of food becoming waste in the first place is clearly extremely important in the Framework:
1.Recommendation (pg. 8-9)
-Consider including an additional objective: “Creating a culture of food waste avoidance”.
-This aligns with reports language (pg. 12) and is consistent with the “Ontario Food Recovery Hierarchy” (pg. 39).
2.Recommendations (General)
-The report should identify and promote the development of food literacy as an antidote to the residential sector’s food waste. This will result in “adopting relevant best practices” (pg. 17) such as regarding “purchasing habits, confusion over expiry and best before dates, as well as preparation , serving and storage practices (pg. 42).
a.Consider articulating clearly that the primary cause of the residential sector’s food waste is the increasing de-skilling of the population in food skills and a cultural shift related to food and food-related activities, both of which are integral to the concept of food literacy.
b.Data collection mechanisms for measuring progress on waste reduction and resource recovery must capture the root causes of residential sector food waste, insufficient food literacy, “to prevent and reduce food and organic waste and assess effectiveness of behavior change with regard to food and organic waste over time” (pg. 17). This will help to provide “Clarification on how prevention … can be counted towards the targets” (pg. 56).
c.Connect with partners working on development and testing of a tool for measuring food literacy. This will support the key guiding principle of “Using evidence to guide decision-making” (pg. 8) and also help with establishing “performance measures” (pg. 57).
d.Consult with appropriate experts “to enhance and incorporate waste reduction and resource recovery activities within schools” (pg. 12) particularly on healthy eating promotion and food literacy principles that support waste prevention, and on development of communications and of workshops and skill-building sessions (pg. 13). This should include consideration of developing a framework for re-instituting food and nutrition courses in secondary schools (http://www.ohea.on.ca/blog/a-call-for-mandatory-food-and-nutrition-cour…) and potentially that requirement for graduation include completion of at least one course/credit that includes food literacy development.
e.Similarly, consult with appropriate experts to support municipalities to “develop and implement their own promotion and education programs aimed at preventing food waste … reaching consumers directly through information that will assist consumers in preventing and reducing food waste” (pg. 43).
•Positioning for food rescue/donations of surplus foods should be clarified in the report.
1.Recommendation (General)
-Food rescue could be more overtly positioned as an appropriate lesser step (after prevention as the first step) to reduce food waste and contribute to food security. Consult with appropriate experts around impacts of incentivizations, systems impacts and unintended consequences depending on the positioning of food rescue.
2.Recommendation (pg. 15)
-Ensure that food rescue is not suggestive of being a solution or appropriate measure to address food insecurity, which is a poverty-induced situation. The statement on this page regarding “building capacity for… social service organizations to safely transport fresh, nutritious food for distribution to those experiencing food insecurity” should be reconsidered.
It is anticipated that a provincial group, Ontario Society of Nutrition Professionals in Public Health (OSNPPH), will be submitting a response to this framework. It is recommended the Province review this submission and consult OSNPPH as a key partner for content, subject matter expertise, and support around data collection.
Food Safety Components:
•Banning of food and organic waste at disposal sites may trigger the “off-loading” of unsafe foods to rescue organizations. Consideration needs to be given to this potentially unintended outcome if a ban is implemented. There appears to be some consideration given to illegal dumping but some should also be given to “off-loading” (pg. 19).
•For resource recovery of organic waste in multi-unit residential dwellings, consideration should be given to odour and pest control (pg. 20).
•The Province should consult with food safety experts in the development of “food safety guidelines to support the safe donation of surplus foods” (pg. 30, bullet #5).
•Clear safety parameters must be set for the distribution of surplus foods – may be addressed in the aforementioned food safety guidelines (pg. 44, section 3.6i).
•In supporting the infrastructure for resource recovery, it appears some consideration will be given to odour control; however some consideration should also be given to pest control (pg. 50-52, Policy 5 and 6).

[Original Comment ID: 211970]