Preventing plastic pollution from pellet loss: supply chain approach

2 The proposed system

The proposed approach is a well-designed system, based on a set of principles, which gives assurance to everyone with an interest in plastic products (including retailers, brand-owners, government, regulators, investors, industry, non-governmental organisations, buyers and the public) that supply chains are handling pellets responsibly and effectively to prevent pollution caused by their loss to the environment.

2.1 Principles of the proposed system

Following discussions with the steering group and interviews with other actors in the supply chain, a set of principles was proposed. These principles should be the basis of a system to ensure it builds on progress to date, underpins a solution that can apply across the full chain of custody and is externally verifiable and transparent.

The proposed system should be based on the following principles:

a The proposed system is built around all organisations carrying out the procedures laid out in the Operation Clean Sweep (OCS) guidance or equivalents. It contains no additional technical standards of its own.

b Organisations of all sizes can participate in the proposed system. No exemptions will be applied to smaller organisations or lower levels of throughput (although assistance may be available, for example from economic development agencies).

c Voluntary participation – organisations are not obliged to participate in the proposed system. However, buyers may include certification as a requirement in their procurement policy. The final system should be compatible with a regulatory approach should that be required, and appropriate, to drive uptake.

d Mandatory disclosure – compliant organisations will be listed on a publicly available online database.

e Centralised accreditation body – organisations can be audited by any certified body, but compliance is logged with a single central authority.

2.2 The scope of the proposed system

The proposed system applies to all forms of pre-production plastic pellets, including recycled material. It is based on a chain-of-custody approach, not simply chain-of-ownership. This means that all companies physically handling pellets, or the products they are made into, must be included to maintain responsibility for the safe handling of this material. Organisations which do not physically handle pellets, or the products they are made into, need not be included.

The chain-of-custody companies includes:

• Industrial businesses that physically handle pellets;
• Companies which handle but do not at any point own the pellets (such as haulage or shipping companies)
• Companies which form part of the supply chain, but which do not physically handle pellets

This includes companies within the following supply chain sectors:

• Plastics industry
  • Resin manufacture, reprocessor;
  • Interim processors of pellets (masterbatchers, compounders);
  • Product and packaging manufacture (converters);
  • Recyclers.
• Logistics industry
  • Warehousing;
  • Haulage;
  • Repackagers;
  • Shipping;
  • Port handling;
  • Port authorities;
  • Retail;
  • Any business selling plastic products.

2.3 Structure of the proposed system

The proposed system is based on several components:

I. Integration into everyday operational practices with recognition that this is a continual process of improvement;

II. Enabling individual sites and operations to demonstrate compliance using standardised best practices based on OCS guidance and accredited external auditors;

III. Creating a chain-of-custody system which ensures only compliant sites and operations are included in the supply chain of compliant products.

Each component is outlined in the following sections.

Figure 1 provides an overview of the system.

2.3.1 Integration of proposed system into everyday operational practices

Integration into the everyday operational practices of the business is a key part of the proposed new system. This is also central to the premise of OCS, which is a toolkit of guidance, procedures and templates developed to help plastic industry operations managers improve worksite set-up to prevent and address spills of pellets, maintain internal procedures to achieve zero pellet loss goals, provide employee training and check performance regularly through a process of continual improvement.

In the UK, OCS is offered as a voluntary solution to pellet handling companies by the British Plastics Federation (BPF). Plastic Europe is the principle host of OCS in Europe and plans to develop an OCS certification scheme^[4].

The proposed system is based on several components: 1. Integration into everyday operational practices with recognition that this is a continual process of improvement; 2. Enabling individual sites and operations to demonstrate compliance using standardised best practices based on OCS guidance and accredited external auditors; 3. Creating a chain-of-custody system which ensures only compliant sites and operations are included in the supply chain of compliant products.

2.3.2 Demonstrating compliance using standardised best practices and accredited external auditors

2.3.2.1 Development of a standardised approach

For companies to be fairly assessed on whether they are handling pellets responsibly, there needs to be an agreed approach. Standards can provide a reliable basis for businesses to share the same expectations about how a product, service or process is carried out – in this instance the management of pellets.

A Publicly Available Specification (PAS) is a fast track standardisation process pioneered by the British Standards Institution (BSI), the UK's national standards body. In early 2020 development of a PAS for pre-production plastics in the supply chain, sponsored by the Scottish Government and others, is set to be initiated. BSI is responsible for managing this well-recognised and consensus-based process. A distinct steering group and review panel for the PAS development process will need to be established to ensure fair and transparent representation of all stakeholders across the supply chain.

Once a standard, such as this PAS, has been developed it can be used directly by auditors to assess the compliance of a site or operation that handles pellets as part of existing audits. Alternatively, it can be used as the basis of a certification scheme which can provide an additional level of guidance, support and recognition.

2.3.2.2 Using accredited external auditors

Under the proposed system, integration of best practice into everyday operational procedures for a business is demonstrated through an annual audit by an accredited external auditor. This could be a standalone process (such as a pellet certification scheme) or integrated into existing audit programmes.

The audit should involve the following process:

Annual (at least) assessment to include:

• Checks of training and operational records and procedures, see Annex A
  for full list
• Visual inspection of the site (or other operation e.g. haulier).

Based on the findings of the assessment, the site (or operation):

• Passes as compliant; or
• Is issued with a non-conformance report, including corrective actions.

If a non-conformance report is issued:

• The site must submit a corrective action plan^[5] within a short period (usually two weeks) to the auditor for approval;
• Once approved, the site must implement this corrective action plan within the agreed timescale (no longer than three months)
• Evidence must be provided to the auditor to show implementation of the corrective action plan within agreed timescales
• If the auditor is then satisfied, the site will be declared compliant
• If the auditor is not satisfied, then the site will be declared non-compliant.

This approach to non-conformance and corrective action will be familiar to companies operating ISO management systems^[6]. Integrating auditing into existing audit programmes, such as ISO 14001, would avoid a company being required to have an additional auditing process, and minimise duplication, disruption and cost where effective systems are already in place. However, if required, a company could choose to adopt a separate standalone scheme. Both should use a standard, such as the PAS, as the basis to ensure continuity in standards across the supply chain.

This approach requires that the system includes a register of accredited, qualified auditors. Alongside the PAS, auditors will be able to make use of OCS guidance to inform their site inspections and assessment of the efficacy of procedures developed by the businesses they are auditing.

Businesses which are part of the plastics supply chain, but do not directly handle pellets themselves, will only need to comply with the chain-of-custody elements of the system.

2.3.3 Creating a chain-of-custody system

The final part of the proposed system is a compliance register. In its simplest form it is essentially an online database of compliant companies. If a business, such as a retailer or brand-owner, wishes to ensure that its plastic products are manufactured in accordance with best practice, it can select a supplier from this database.

For a supplier that does not handle pellets itself, registration will be straightforward and require procurement from compliant suppliers. Companies that do handle pellets must operate a management system which incorporates, at a minimum, the checks of training and operational records and procedures outlined under the auditing requirements above (and listed in Annex A).

A compliance register system can automate the process of keeping records of materials purchased and whether they come from a compliant supplier. It can also act as a hub for tracking materials and handover points. This would help streamline the whole process and opens the possibility of analysing the data to identify high-risk activities, locations and even operators. This information would be confidential but would provide the system operator and subscribers with valuable insights to accelerate improvements in pellet management.

A digital compliance register also provides a way to automatically calculate the percentage of compliant material in finished products, which would be necessary to implement the scheme. Further work is needed to fully consider how this would apply if, for example, there was a link in the supply chain which was not compliant. Potentially a temporary 'patch' could be applied, particularly in the early stages of implementation, to prevent breaking the chain in an otherwise compliant supply chain. The Scottish Government's steering group wish to explore these options further. Further details and discussions about elements of a compliance register are included in the main report.