Subpar waste diversion results in Ontario’s ICI and multi-residential sectors are hobbling ambitious targets to conserve existing landfill capacity. Newly released recommendations from provincial Auditor General Bonnie Lysyk call for more outreach, enhanced data and firmer oversight to improve compliance with recycling regulations.

It’s currently estimated that about 50 per cent of waste generated from Ontario’s single-family households and other sources eligible for municipal collection services is diverted from landfill through recycling programs for various inorganic and organic materials. In contrast, about 85 per cent of waste from an array of businesses, public institutions, residential buildings with six or more units and construction/demolition sites ends up in landfill, including a vast amount of recyclable material.

The value-for-money audit of waste reduction and diversion — one of five released earlier this week as part of the Auditor General’s annual environmental review — concludes that Ontario came close to meeting its 2020 objective to divert 30 per cent of generated waste from landfill on the strength of the residential contribution. However, it is well off-pace to achieve stated targets of 50 per cent diversion by 2030 and 80 per cent diversion by 2050.

“If Ontario continues on its current trajectory of waste generation and disposal, existing landfill capacity in the province will be filled within the next 11 to 14 years,” the audit report projects. “Our audit found that improving waste management in the IC&I sector — which generates and disposes of the majority of Ontario’s waste — holds the key to meeting the province’s waste goals, as well as to avoiding Ontario’s looming landfill shortage.”

As recommended, that would involve a three-pronged approach of: 1) expanding the base of regulated entities required to recycle, conduct waste audits and implement waste reduction plans; 2) providing more resources for compliance and beefing up enforcement of regulations; and 3) mandating a broader range of materials to be recycled.

Many businesses and institutions exempt from recycling obligations

The current triggers for imposing mandatory recycling and waste reduction obligations are meant to target the largest waste producers, but the audit report calculates that up to 98 per cent of organizations in the ICI sector are not captured. Exempt entities are believed to be collectively responsible for generating more than half of the sector’s waste volume.

For example, while the six-unit threshold arguably brings the major share of multi-residential properties into the scheme, office buildings and retail malls, plazas or stores are exempt until they surpass 107,000 square feet (10,000 square metres) in size. The same goes for construction and demolition sites smaller than 21,500 square feet (2,000 square metres), hotels and motels with fewer than 75 rooms, and schools with fewer than 350 students.

“More than 98 per cent of businesses and institutions are not required to recycle, so they often don’t,” Lysyk submits. “Sending waste to landfills is relatively cheap, so even easily recyclable products from places like offices, restaurants, movie theatres, retail stores and warehouses end up as landfill garbage.”

The remaining 2 per cent encompasses about 7,000 office buildings, 3,000 educational facilities, 1,500 manufacturing facilities, 1,500 to 4,000 retail venues, 800 hotels/motels and 100 hospitals. The report estimates that 100 to 600 qualifying construction or demolition sites in 2019 represented less than 1 per cent of such worksites in the province that year.

The audit reveals varying commitment to compliance among those players. Data for approximately 1,260 inspections the Ministry of Environment conducted in the five-year period ending in 2019 shows an overall 88 per cent compliance rate with building-level requirements to separate out recyclable materials from the waste stream, with office and multi-residential buildings both surpassing that average.

Waste audit figures for the same period provide more insight. Multi-residential buildings are not subject to requirements for self-reported audits and waste reduction plans, but office buildings demonstrate a wide range of performance — from a low of 36 per cent to a high of 90 per cent waste diversion. That’s a pattern seen elsewhere, with universities exhibiting one of the widest swings from a low of 11 per cent to a high of 81 per cent diversion.

Neither quality control nor record-keeping enforced through inspections

The report notes that inspectors look for designated bins for recyclable materials and waste as evidence of source separation, but typically do not check to ensure recyclable material is uncontaminated with waste or organics. Nor do they require record-keeping to show that recyclables are shipped to legitimate recycling facilities.

“Broad compliance with the Source Separation Regulation does not necessarily result in higher waste diversion. The regulation does not require establishments to achieve a specific performance outcome, such as a diversion target, only to make ‘reasonable efforts’ to divert collected materials,” the audit report states.

It suggests the government’s pullback on requirements for audits and reduction plans could be part of that disconnect. Since April 2019, Ministry inspectors have focused only on the rules for separating recyclable and waste materials, downplaying the documentation and planning exercises that are meant to steer participants’ attention to opportunities to curb waste and increase diversion.

The audit also raises serious concerns about where much of the recyclable material goes after it is sorted out at buildings — deducing that it often ends up in landfill because it is taken to transfer stations that aren’t equipped to handle it. In response, the report calls for more data and transparency.

“Establishments do not have access to information about waste industry activities to verify where recyclables are taken or to make informed decisions when contracting waste services,” it states. “The Ministry does not compile or publish information about waste management companies’ operations, such as their diversion rates, the types of materials they divert, or what they do with the materials they handle.”

The Ministry is urged to update its 25-year-old list of mandated materials for recycling to add the coffee cups, compostable packaging and an expanded range of plastics that it is now feasible to recycle, and to more actively promote looming targets for diverting organic waste in the ICI and multi-residential sectors. The latter were invoked through the 2018 organic waste policy.

“The policy requires multi-residential buildings and large establishments to reduce and divert organic waste by either 50 per cent or 70 per cent, depending on their size and subsector, by 2025,” the audit advises. “This could result in added costs for the affected multi-residential buildings and establishments that require budgeting, but the Ministry has not yet provided essential guidance on how to calculate the baseline for the target, nor undertaken outreach activities to promote compliance with the policy.”