Phil, you have many different titles in the industry, can you briefly outline what you do and how you have got to where you are?
After studying Industrial Management at Leeds University in the early 1980s, I developed my family business – reconditioning & recycling used industrial packaging – working in the yard and driving lorries for a number of years before taking on Management responsibilities such as writing the BS5750 (now ISO 9001) Quality Management Manual. When took over the role of Managing Director in 1992, I commissioned the construction of a new, purpose-built factory, incorporating the latest environmental features. As part of my business and personal development I also qualified as a Hazardous Waste Manager in 1998, a Dangerous Goods Safety Adviser in 1999 and later become a Chartered Environmentalist in 2004. As a successful business, the company was sold in 1999 to a drum and IBC manufacturer for whom I worked as a Technical Director for several years before setting up my own consultancy as a Dangerous Goods Packaging / Transport & Hazardous Waste Adviser.
In 2004, I was approached by the heads of the Association of Drum Manufacturers (ADM), Rigid IBC Association (RIBCA) and the Federation of Container & Drum Reconditioners (FCDR), to act as the CEO of their proposed new joint-trade association; The Industrial Packaging Association (IPA) – a role which I am privileged to continue holding today.
In 2005 I was invited to act as the Secretariat for the European Association of Fibre Drum Manufacturers (SEFFI) and subsequently also became involved in the European Industrial Packaging Association (EIPA) and the International Confederation of Plastics Producers (ICPP).
A core part of my role for the Industrial Packaging Sector, is to represent the industry within Government and the various regulatory and enforcement bodies, hence I also hold various committee positions, including; Chair of BSI Standards Committees on Packaging & Environment (inc work within CEN Packaging Committees and UK Lead at ISO Packaging & Environment), Drums also IBC Standards (mirrored with similar committees within CEN), Chair of the VCA Dangerous Goods Packaging Scheme Review Committee (PSRC), and also as a member of the DEFRA Advisory Committee on Packaging (ACP).
In my spare time I work as a Pre-Hospital Trauma Medic for various motorsport events and film / television productions. I also enjoy skiing, hiking, underwater photography, teaching scuba diving, teaching First Aid at Work courses…. I’m rarely bored!
As the Chair: Packaging & Environment at British Standards Institute, do you specialise in Safety and Environmental Expertise?
Not quite – although I do have some knowledge of Health & Safety requirements, my work within the BSI Packaging & Environment Committee has been focused on the development of the new ISO standards, of the same title, over the past 5 years. This has not been an easy task as the CEN standards are now quite outdated and have not been good for the industrial packaging sector. Also, some of the EU phrases do not sit easily within an international context and had to be reconsidered for the ISO documents. The CEN standards are now also being considered for any changes that may be required in consideration of ISO.
What’s the purpose of your organisation?
Both the Industrial Packaging Association (IPA) and the EU Fibre Drum Manufacturers’ Association (SEFFI), exist to promote, preserve and protect the manufacture, reuse and recycling of industrial packaging. This includes working to ensure that rules, regulations, standards, and real-world enforcement issues work in a positive way for our industry and its customer-base on a national, European and international level both now and in the future.
What interesting developments can you tell us about?
The new international (ISO) standards on Packaging & Environment are published, which includes the latest thinking on; how the various standards interact, the reuse of packaging, materials recycling, energy recovery and organic recovery. The focus is very much away from considering used packaging (specially industrial) as `waste’ and more of a valuable resource – hence there was a strong focus on the reuse aspects, for which industrial packaging is excellent and has a long standing history.
One key, current concern is the crushing and bailing of emptied but uncleaned packaging. With such a strong emphasis on recycling, many companies have been encouraged, even obliged by the outdated EU Packaging & Packaging Waste Directive, to send their used packaging for recycling – which by definition is destructive, such as scrapping, melting etc. Following a long-standing campaign by the IPA for a more enlightened and environmentally efficient approach, it is now a requirement that all used packaging must be consigned according to the waste hierarchy of reduce, reuse, recycle, recover. This means that, if an industrial container is suitable for reuse, it should be consigned as such.
Unfortunately, there remains a number of companies who are bailing or crushing their emptied but uncleaned packaging – which therefore retains some residual content. In a household context, items such as food and drink cartons don’t often present any real problems, apart from a few unpleasant odours as the food residues break down. However, with industrial packaging, we often have concentrated products with hazardous and dangerous properties . Consider that even citrus flavourings are often flammable and some popular drinks products constituents are corrosive. To crush or bail these packagings and send directly to a recycling site is both dangerous, environmentally inefficient and does not even make good commercial sense.
To crush or bail a used container which retains any hazardous residues is irresponsible and potentially breaks several safety and transport laws. It is of course usually impossible to read any hazard warning labels on crushed or bailed packaging – hence nobody from that point onward knows what they are handling. The act of bailing and crushing usually means the packaging will split at some point, allowing any residues to escape. I have personally seen a bail of emptied plastics packaging with (what turned out to be) oxidising chemicals leak and react to start a fire – which was fortunately extinguished before it became a serious incident. To transport empty, uncleaned packaging with dangerous goods residues without being able to read the relevant labelling breaks the rules on transport of dangerous goods – putting the consignor and driver at risk of prosecution. Many scrap yards and recycling sites are not equipped for cleaning / handling hazardous products and therefore not licensed for that work – again putting all parties at risk of prosecution as well as the safety risks.
Used industrial packaging, such as drums and IBCs should be consigned to a properly waste-management licensed reconditioning company, where the containers can be properly cleaned of the residues then individually assessed to determine suitability for reuse (for which the consigner may get a credit higher than the scrap alternative) or, if they are not reusable then they will be sent for recycling as a clean and safe item.
What effect is the rise in energy and raw material prices having on the industry?
Packaging is of course an essential means by which products are delivered to customers. Industrial Packaging performs this function in an extremely efficient way – from both an environmental and cost-effective perspective. However, as with any manufactured item, the production costs are hugely affected by the cost of both raw materials and energy. The unprecedented rises in costs we have seen over the past years have resulted in a number of packaging companies closing sites or merging with others to try benefit from economies of scale and logistics. In past years some packaging manufacturers have tried to lower their prices by making lighter-weight drums and IBCs, but this has proven to be short-sighted as this reduces the life-cycle of many packagings and hence the inherent value. Buyers of packaging have recognised the very real value of reusable packaging and the benefits in both cost and ease of disposal. This has had the effect that industrial packaging manufacturers, rather than concentrating on designing lighter-weight products, are forming alliances and mergers with reconditioning companies, so they can offer both new and refurbished products to their customers and a take-back service for the end-users – which is real added value to the whole chain of use and of course the environment also benefits.
What about in terms of the manufacturing of IBCs?
Considering the Rigid, Composite IBCs that are now a key part of most liquids and powders manufacture and distribution chain, we have seen a number of advances in both manufacturing techniques and materials technology. Multi-layer moulding is now well established and can provide various benefits such as solvent resistance and anti-static properties. Also, with the composite units, it is of course possible not only to clean and reuse the IBC but also replace any components that may be worn or damaged – allowing the unit to continue at a minimum cost of maintenance. Many IBC manufacturers offer a take-back service to customers and end-users. This is of course also available from independent reconditioners and many of these are forming close working relationships with the IBC manufacturers to ensure the best possible standards are maintained through use of approved components.
What is done by the manufacturers to ensure its safe operation?
Both drum and IBC manufacturers operate to very high standards, with controls to ensure consistency and quality are maintained day to day. This includes in-house, on-site testing facilities with the required calibration and training systems to meet UN standards for Dangerous Goods. Customer visits and audits are now an integral part of the supplier-client relationship and we have seen a variety of design variations being created to meet individual customer requirements – where possible. Many manufacturers are now operating to standards required by the food-hygiene regulations and, with an ever tightening grip of production costs, manufacturers are striving to become even more efficient in their production methods – which means better process control, less waste and improved product consistency and safety.
Can anything more be done?
It is good to see that we are, at last leaving the old days of bitter rivalry between industrial packaging manufacturers and reconditioners behind us – where each saw the other as a competitor for every sale. Manufacturers and reconditioners are now learning from each other to see how the whole chain of use can benefit from the very start of new design, manufacturing techniques, component replacement and inter-changeability and the logistics of delivery and collection – not just locally but on an international basis. Industrial packaging is truly global and continues to develop internationally consistent products, services and logistics. The retail sector of packaging has never been able to offer such an amazing system for world-wide interaction and recovery of packaging.
Reconditioning of IBCs is obviously the more sustainable option at the outset…
The reconditioning and reuse of both drums and IBCs is of course a very environmentally efficient and cost-effective service, available on a world-wide basis. The development of the new ISO Standards for Packaging & Environment was attended by more representatives of the industrial packaging sector than ever before – reflecting on the international importance of this service. The ISO standards make a key deviation from the CEN standards in that the word “reduce” is no longer used. This is because it is recognised that to simply reduce the materials in packaging may often not be the most efficient option – this is especially true for drums and IBCs. What we need to consider when designing industrial packaging is how it can be optimised to ensure both safety and efficiency during its lifetime of use and also how it might be ultimately have its materials recycled or recovered at the end of its use as a container.
Reconditioning is now a very professional and key element of all industrial packaging design, manufacture, supply and use on an international basis. This is reflected in both the way the major manufacturers and reconditioners are working together and the development of international logistics for collection, reconditioning and reuse, plus the work on ensuring standards and regulations are developed to reflect and support this sector.
Can you estimate what percentage of eligible used IBCs are being reconditioned?
This does of course vary greatly as it is dependent upon several factors. There is a difference between reuse for same, similar or compatible products and what is required of reconditioning for sale and use with a completely different, unrelated product. The type of product to be contained is also a key consideration, be it a low value or non-Dangerous Goods product or an expensive, specialised product with hazardous properties.
Then it must be considered what product the IBC contains, as some specialist resins, pigments and aggressive chemicals can mean the IBC may not be suited for reuse. However it does of course remain important that these IBCs are cleaned and inspected to ensure they are ok for safe recycling – as mentioned previously.
It does vary from country to country – dependant on the infrastructure and logistics, but of those eligible and where there is a good infrastructure of reconditioning services, I would estimate that at least 80% of IBCs are being collected and refurbished / reconditioned for reuse. We need to continue developing the type of services we see within Europe, the USA and Japan to encourage increasing volumes of collection and reuse. In spite of the sheer scale of geography both Australia and South Africa are rapidly developing their collection and reconditioning infrastructures – with others such as South America and China following closely.
Are there any dangers with the process?
As a Hazardous Waste Manager and Dangerous Goods Safety Adviser, my personal and principal concern is that there are some reconditioners who are simply not properly licensed, equipped or trained to handle some of the chemical residues within the used drums and IBCs they offer to receive. The reconditioning of used packaging is actually a complex and technically difficult operation. To carry out a professional level of reconditioning for used chemicals packaging a company must comply with several differing rules, regulations and training requirements – including handling of hazardous chemicals (from both a health and safety and also a waste management perspective), knowledge of drum and IBC types and designs for stock segregation, how different products affect the packaging materials and the possibility for cleaning and removal, plus the rules on selection, reconditioning, testing and marking for UN compliance if to be used for Dangerous Goods products. There are several very high-quality reconditioners that meet all these requirements, but also a number who do not. I would therefore encourage any end-user to visit and audit the company where they wish to consign any used packaging – whether for reconditioning or for scrap recycling.
What issues arise when the EA (Environment Agency) meets the HSE (Heath & Safety Executive)?
At the risk of being controversial, my main problem is that the EA doe not liaise with the HSE enough – if at all from my experience. I have witnessed several cases where an Environment Officer is more than happy to see something that might comply with a waste rule but is clearly in breach of an transport or health and safety law. There is clearly not enough training of front-line enforcement staff. The IPA and its members have raised several cases of known illegal activity to the EA and the HSE, but this has resulted in little action being taken – in spite of both Agencies stating they rely on industry to help police itself and advise of any suspected illegal activity.
In one case, the EA were advised of illegal handling of hazardous chemicals packaging – to which their reaction was to make an appointment to visit the site some weeks hence. Needless to say all was fine on arrival!. When we pressed the point and an unannounced spot-check was carried out some time later, the illegal practices were found (in spite of such an earlier warning) and some action taken. During all of which time the professional operators have to compete in terms of the high costs for maintaining correct compliance, management and resources!
The IPA are working with the HSE, EA and DEFRA to try develop better understanding of the real-world issues we are facing and the need for effective enforcement. There is simply no point in developing impressive regulations and standards if the front-line enforcement isn’t both knowledgeable and effective.
What are the legal issues surrounding this situation?
If hazardous chemicals packaging is crushed or bailed and the relevant labels cannot be read, then this packaging cannot be transported – as it would contravene the rules on Transport of Dangerous Goods ie; CGD & ADR. Any leakage (quite likely with crushed packaging) of such residues would also contravene not only the transport laws but also the laws on waste handling and consignment but of course several basic health & safety regulations. Responsibility lies with the consignor, the carrier and the receiver of such packaging – so all parts of the consignment chain will be held responsible if the correct rules are not followed.
What are the moral issues?
Morally we have a Duty of Care not only for our environment but for the safety of everyone involved in our packaging use, reuse and ultimate disposal / recycling. The fact is that it is actually very beneficial to take the extra care. Environmental efficiency is directly linked to economic efficiency – both in direct terms of saving costs and indirectly avoiding costly problems, investigations and potential prosecutions and loss of reputation etc.
I have witnessed several cases where a corporate buyer has made a `saving’ of a few pounds by lowering the specification of a drum or IBC the company was buying – only to later discover that the actual reality was a loss, as the value of the emptied container was either reduced, lost completely or even resulted in a disposal cost because the packaging was no longer suited for reuse. We have to be more switched onto the life-cycle and true cost of what we do. One of my recent audits took a single day but saved the client over £80k per year through simply considering the true life-cycle value of their packaging.
In general, why has all of this not been addressed before?
In some cases it has been addressed before, but then a new buyer comes in without the same experience, background or knowledge and tries to make a short-term or short-sighted impact. It can often simply be that companies have not considered what they previously regarded as `waste’ packaging to actually be a resource, with an actual value. That is one of the key reasons the title for the new ISO Standards on Packaging & Environment does not include the word `waste’. We must also consider the advances made by both industrial packaging manufacturers and reconditioners over the years – in design and processing techniques that enable more drums and IBCs to be reused than previously possible.
Apart from the obvious difference in capacity, are there fundamental differences between the safety risks associated with the handling of IBCs and those of Drums?
Both drums and IBCs have an incredible and enviable safety record for the international transport of an incredibly wide range of products – by road, rail, sea and air. It is always a shame when some of the less-informed media show a pollution problem through use of a photograph of a discarded or damaged drum or IBC. The simple fact is that many millions of trips are carried out every day or every week by both drums and IBCs as new and reconditioned without any incident. It is this high standard of safety that has meant the basic design of both drums and IBCs has remained consistent and internationally respected for so many years.
What do you and your organisation strive to achieve in, say, the next 5 years?
It has always seemed unusual to me that, in the UK, we have a Department for Transport Approved scheme for the Reconditioning of drums, which are typically 210 litres with the closure in the top, to meet UN standards for use with Dangerous Goods, yet we do not (yet)have such a scheme for IBCs, which are typically 1000 litres with closures in both top and base! The UK Reconditioners’ scheme for UN drums has proved hugely successful – with close controls and audits carried out on the training, documentation, equipment calibration and marking methods used to ensure and maintain the highest standards. In my personal consideration this same type of scheme would also prove to be of even greater benefit for the reconditioning – or to use the correct terminology; the remanufacture, repair or routine maintenance of IBCs.
I would like to see an expansion of approved schemes for reconditioners across UK, Europe and beyond – to highlight the professional standards being achieved by industrial container reconditioning companies such as are members of IPA in the UK, SERRED in Europe and RIPA in the USA.
I would also like to see more interaction and cooperation between not only between the drum and IBC manufacturers and reconditioners but also with the industry regulators and enforcement agencies – as this is the true way by which we can continue to improve and through which we will gain even higher standards, business efficiencies and environmental care.