January 15, 2018…

January 15, 2018
Mr. Ian Drew
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Resource Recovery Policy Branch
40 St. Clair Avenue West, Floor 8
Toronto Ontario, M4V1M2
ian.drew@ontario.ca
Re: Proposed Food and Organic Waste Framework, November 2017
Dear Mr. Drew,
In the effort to ensure that food and organic waste is diverted from landfill and that recovered organic material can be used to help Ontario move towards a circular economy, we believe that the province has dismissed an important tool in helping achieve its food and organic waste framework goals. Under-the-sink Food Waste Disposers (FWD) play an important role as a consumer-friendly household appliance that helps to achieve food waste diversion and environmental goals. Studies clearly show that convenience is a key factor in supporting effective and continuing participation by residents in diversion and recycling programs. In-sink kitchen disposers provide convenience in exactly the location that food preparation and dish cleaning takes place, which is why they are such popular appliances.
The Association of Home Appliance Manufacturers Canada (AHAM Canada) is the industry trade association representing the manufacturers of major, portable and floor care home appliances, and suppliers to the industry. AHAM membership includes over 150 companies throughout the world. AHAM members employ hundreds of people in Ontario and produce more than 95% of the household appliances shipped for sale. The home appliance industry, through its products and innovation, is essential to consumer lifestyle, health, safety and convenience. Home appliances are a success story in terms of energy efficiency and environmental protection.
Compostable Products and Packaging
Although the proposed Food and Organic Waste Framework has a section on compostable products and packaging (CPP), the discussion is at a very high level and provides little specificity. Part B Section 5 introduces and briefly discusses the use of CPP, however, little in the way of policy that would encourage greater use of CPP is provided. In order to encourage greater use and introduction of CPP, changes to Stewardship Ontario’s Blue Box Plan will be needed. Under the present Ontario Blue Box rules, there is no positive business case to introduce compostable packaging with a lower life cycle and environmental impact. Compostable packaging is not provided with preferential treatment by the blue box program, and depending on the type of packaging it is even labelled as disruptive packaging. Eliminating obligations or drafting specific exemptions of fees for compostable packaging would provide an incentive for its use. Stewardship Ontario’s rules are focused on present capabilities of materials recovery facilities and end market recyclable value, not lower net environmental impact. A more comprehensive CPP strategy, that includes recognized international biodegradability and compostable standards, would greatly improve the economics for compostable and bio based products and packaging would contribute to a more sustainable approach moving forward.
Benefits of Food Waste Disposers
Our concern in representing appliance manufacturers is the adoption of bans or restrictions of internationally and nationally recognized and regulated products without a full and comprehensive evidence-based assessment of their benefits. The Policy Statement specifically indicates that food waste conveyed to the sewer system by Ontarians use of GarburatorsTM or grinding devices, (aka food waste disposers), will not be considered for the purposes of achieving targets. The message conveyed in clause 2.5 is that FWD will play no role in helping Ontarians divert food waste from landfill. That statement appears arbitrary. There is no explanation or rationale provided why FWD have been specifically excluded as a tool for helping to divert food from landfills, nor any evidence that other approaches are more successful. The implicit message to Ontarians is ‘don’t install or use FWDs’.

The exclusion of FWD as a tool to help divert food waste from landfills is all the more puzzling given the difficulty of collecting food and organic waste from multi-residential buildings. Throughout the proposed framework, the analysis indicates that diversion of food and organic waste from multi-residential buildings poses a slew of difficulties. In fact, FWDs are an ideal tool to help divert food wastes in such buildings. As opposed to dismissing FWD contributions to diverting food waste from landfills, the Province of Ontario should be looking at ways that disposers can be incorporated into the province’s framework - a far better outcome than sending those food wastes to landfill to decompose and release the potent greenhouse gas methane. In fact, as of Jan 1, 2016 the City of Philadelphia amended their building code to require the installation of in-sink food waste disposers in new residential housing.
FWD are an effective complement to a city’s curbside organics collection program and can help the province achieve its goals. Food scraps and organic material should be considered a resource not a waste. At modern wastewater treatment facilities, methane is produced by anaerobic digestion. The organic material can be recycled into renewable energy and the residual organics (food and other organic wastes) can be further processed into fertilizer. The high carbon content of the food slurry is the ideal organic material for anaerobic digestion.
In addition to these benefits, the use of disposers offer additional benefits including reduced emissions associated with transporting organic waste, cleaner cities and fewer pests. Disposers require a very small amount of electricity and water to operate. AHAM estimates that disposers account for less than 1% of a household’s total water consumption. Additionally the electrical consumption of a disposer is no more than 3-4 KWh per year. The perception that disposers consume excessive resources is clearly not substantiated.
AHAM member companies devote substantial engineering expertise and research resources to understanding the use of their products, and collaborate with a wide range of stakeholders, academic experts, and professional associations. We believe that the technical and best practice research that can be provided by AHAM member companies for your consideration will clearly demonstrate that FWD can play a useful and compelling role. We would like to work with the Government of Ontario to resolve any misconceptions regarding the use of FWD prior to the Food and Organic Waste Framework being finalized.
Thank you for your consideration.

Sincerely yours,

Bruce Rebel
Vice-President and General Manager
CC:
Dr. Wendy Ren
Director, Resource Recovery Policy Branch
Ministry of Environment and Climate Change

[Original Comment ID: 212020]