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The National Waste & Recycling Association (“NWRA”) submitted March 1st comments on the Solid Waste Environmental Excellence Protocol (“SWEEP”).

SWEEP has been described as a Municipal Standard which evaluates the environmental, economic, and social aspects of delivering municipal solid waste activities.

SWEEP describes itself as a market transformation standard targeting municipalities and waste management service providers to identify and reward leaders in Sustainable Materials Management. It is also stated to define a roadmap to evaluate comprehensive policies and calculate achievement metrics. Further, it is stated to provide performance benchmarks for sustainable waste collection, recovery and disposal practices in technologies.

The Municipal Standard is composed of six performance categories which include:

• Sustainable Material Management Policy
• Waste Generation and Prevention
• Solid Waste Collection
• Post-Collection Recovery
• Post-Collection Disposal
• Innovation

A separate innovation performance category recognizes measures and approaches that are beyond best practice.

The draft standard was developed by SWEEP voluntary committees.

NWRA describes its March 1st comments as cursory as opposed to comprehensive. The organization indicates an understanding that SWEEP may not be accepting comments on the draft standard.

The NWRA’s comments state:

• SWEEP executive description indicates that the standard would evaluate various aspects of municipal solid waste services (noting it is unclear to whom the standard applies and more discussion on the issue would be beneficial)
• The national meeting included significant dialog on SWEEP constituting a leadership standard (asking whether the standard requires commitments for improvements regardless of how developed a program is)
• The standard could benefit from a list of definitions, including:
  • Beneficial utilization
  • Compostable
  • Environmental footprint
  • Sustainable materials management
• Referencing the standard including a greenhouse gas footprint for the baseline year of 2015 (asking why there is no baseline to compare other criteria, such as waste prevention or worker injuries
• The standard includes a section on reducing posting contamination/residue rates (asking whether this applies to the contamination in the processed materials or the overall facility residue rate)
• Referencing NWRA serving as the Secretariat to ANSI Z245 Equipment Technology and Operations for Waste and Recyclable Materials

A copy of the NWRA comments can be found here.