Investigating the Agricultural Use and Disposal of Plastics in Malta

Appendix B.3. Stakeholder Interview Transcripts

Interviewee 1: Environment and Resources Authority, Waste Policy Interview—Environment protection Officer for Waste Policy

As you said, the specific policy for this kind of waste is quite limited. Of course, this does not mean that this type of waste is not regulated in any way. As such, from a policy point of view, policy is the thing; to create a policy, I need to have some kind of information on which the policy itself is based. Now of course, unfortunately, even the information we have about plastic from agriculture is quite limited, which means that with this information, I am talking about how much data is generated. I’m not saying I don’t have data, but its accuracy has never been questioned so well that we can determine how much it reflects reality. This type of waste is classified under a particular code referring to plastic from agriculture, some kind of input is recorded under this type of waste, but they are not large amounts that sometimes again question a sector like agriculture, where the use of plastic is what it means to be used in the greenhouse, also irrigations, in short, how to record such a small amount compared to the amount to be expected, apart from that there is no policy, even the information so that we can be developed in policy is quite limited. I think that’s one of the main reasons why maybe it never came, there were never put forward policies, or else there was an intention to have a specific policy on that. Not only in Malta, but also on the part of the EU institution, there has never been a push for a specific policy on this type of waste.

2.

When you say it is already being recorded to an extent using Malta is this type of data being recorded?

Obviously in Malta when it comes to waste, when it comes to environmental reporting, mainly capture data from, especially when it comes to waste we are discussing, from waste management facilities, which are the main actors when it comes to waste management, where they report the amounts of waste they accept on-site, the origin of the waste as well as the faith of the waste, in this case, it is recorded under specific EWC codes and of course, we know that it is this type of plastic waste that comes from agriculture. In addition, there will be some recorded data, facilities, facilities, whatever, I am talking about waste management facilities which are covered by an environmental permit, and these have the requirement to report this data, especially data on waste, mainly reporting off-site transfer of waste. In addition, then there are exports of some waste where if there is a transport of this type of waste, it is recorded through un-access before the export. Those are mainly the sources of how such waste can be recorded.

3.

Part of the question, do you think there is a need for some kind of policy in the future, and do you want to check the data before saying that it is necessary or not necessary?

I understand this in the sense that if you first create a policy to see exactly what is needed, you need to have a clear picture of the current situation. Once you have a clear picture, it will be easier to see what kind of processes are needed so that all kinds of waste can be handled in the best possible way and apart from that, if it can be this type. Waste is not generated in the first place. Now of course, it is not always possible due to the industry itself and the sector, but of course, you need to have a clear picture of what waste is being generated and the amounts that are being generated so that you can create a policy based on facts.

4.

Given your experience with environmental policy, what kind of policy tool or scheme would be ideal to tackle agricultural plastic waste in terms of reduction and accountability? Again of course, we are saying if there is enough data, action will be taken in terms of a policy or a scheme. In your experience, what do you think would be ideal to reduce plastics in the industry or increase accountability, from the producer himself would have more responsibility perhaps?

Of course, when it comes to waste, it will always be based on the principle that the producer pays; ideally, the one who generates the waste is responsible for the management and treatment of waste, as well as other waste streams that are perhaps more visible during everyday life. This type of waste is being managed under EPR, where the producer who is putting this type of waste on the market remains responsible, even after this material becomes waste; therefore, I think the responsibility of the producer is important, even when it comes to the management of waste, and I think policies to be as effective as possible must be given a certain responsibility, even to the producer himself. We need to determine what we mean by a producer because it may be how you are selling the product in the first place, or it may be how you are using it needs to be determined to understand exactly how it is being used and what type of process is there before it is placed on the market whether it is being manufactured in Malta, or even being imported, these are all variables, which of course one then decides if exactly how the material producer is defined.

5.

So the term producer changes, depending on the industry in a way or?

To some extent, this is the case. For example, the construction and demolishing waste strategy identifies developers as producers. The EPR scheme under packaging or WEEE identifies the importer placing on the market as the producer as such; unless there is a definition at the EU level, the producer can be defined according to the sector and the industry you are talking about.

6.

So it looks like there has to be some kind of EPR scheme or policy tailored to the agriculture.

Yes, exactly. To better implement the producer pays principles, or even policy to encourage reuse of certain items.

7.

If I am not mistaken, there is a concept of reuse for the green plastic crates?

Yes, the Pitkalija usually have a washing process so that they can keep on reusing, but at the end of the day, they deteriorate or become too brittle with the sun; many farmers mentioned that most of them try to reuse as much as possible because the costs are of the material is huge the first to start with how much money they spend on plastic pipes, mulching etc. The intention to reuse them may not be for environmental reasons, but for economic reasons.

Often, when we talk about reuse, and these kinds of best practices there are economic reasons behind them, but it does not mean that there are no environmental benefits that are paired through the same systems. There is also another example of plastic crates made from a certain type of plastic which has a much higher recyclability than, for example, the plastic film used in greenhouses. The options of not reusing after that are they are limited, even on plastic pipes for irrigation, so PVC will probably be those.

That is an example because you have a lot of mulching which is heat resistance or UV resistance. Their recyclability rate of being melted down and reused is difficult because you have two different resins mixed, not as much as one resin that is melted and remelted into something else. And I mentioned accountability, obviously, because I’m tackling disposal patterns. If people who currently have the sticker of the middleman enter the Civic Amenity sites of Ta’ Qali. However, those who are part-time farmers who do not sell to middlemen do not have this accessibility. So, what becomes of it? It’s not being accounted for; it’s not being disposed of probably in illegal disposal sites, so what happens? Will it burn? Will it be plowed in the field? There are these questions that I’m addressing, slowly; of course, there’s a scheme that in a way accounts for these loopholes. That’s why I mentioned accountability schemes. At first, it seems to entice the farmer; they become more transparent because, of course, if you say listen to it, you need to become transparent, and I will increase the cost; no one would want to be part of that.

Interviewee 2: ERA EPR compliance and enforcement—Team Manager (waste schemes and exports).

• With the ERP scheme for the Maltese islands, was agricultural plastic ever considered to be implemented within the scheme? And if not, what was the reason?

When it comes to EPR for plastics, we are only talking about packaging. To explain myself better—if you have a mobile, you have the mobile in a box with the outer plastic; usually, the mobile phone boxes come in a bigger box, and the pallet and shrink wrap around that is all packaging, i.e., here, we are talking about packaging related to products that are put on the market, i.e., the plastic we are talking about. The fields that look like a small tent for you to grow produce are not in the EPR. They are not considered; they are not packaging material of products that will end up with the consumer, but that plastic is good to be collected and recycled, if it is obviously of recyclable quality. Perhaps you can get into the scheme, as you said; for example, pallets or plastic that are rolled up with pipes, for example, but not plastic. So, it was never included in the EPR scheme because it is not packaging.

2.

Do you think the involvement of agricultural plastic waste within the EPR scheme would deter importers from putting on the market as many plastic-related products?

If we have products that are related to agricultural use fall under EPR if they are produced but, we are not talking about that plastic that makes tents with it to be able to grow vegetables in it or irrigation pipes. Like strawberry plastic containers, plastic sometimes comes in this soil: weed peat and be in a bag, that’s plastic; it’s surrounding the product itself. The plastic that grows to make the grass in it is the product its loan, that is, there may be things related to agriculture that are in the EPR, if it is packaging, for example, the tanks. The little ones come with pesticides; that’s packaging. That comes in a bigger box. Comes on a pallet. That’s all the packaging.

3.

If we were to do something similar to the EPR for agricultural plastics, do you think that is possible? Do you think it is feasible? Or at least nothing?

Well, most of the amounts from these plastic products and packaging are also probably catching agricultural items. I’m not saying that the thin plastic that is used to wrap crops and or those used to grow vegetables in it are not trapped in the scheme. Let’s start with the fact that this type of material is usually very dirty because when you put it in the soil, even though it is very large, it is dirty and unfit for recycling. Though it can be washed, one to see if it is viable to wash it.

4.

Are these types of plastics exported, in your experience?

5.

So, since farmers can enter Wasteserv’s civic amenity site at Ta’ Qali, does this mean that Wasteserv then exports the waste abroad?

6.

So to conclude, do you think that it is viable to have, for instance, a scheme to register or control the producer of agricultural plastic waste, i.e., if I am selling plastic pipes or mulching, do you think there should be a type of scheme to give more accountability for its collection or reuse?

Well, the scheme is aimed at packaging plastics, so they target general products and not just one sector because it is difficult. If focus on one sector, you would leave the other sector out. So, they made it as packaging plastics so that it ends up at the consumer. I think if one would focus just on agriculture, it would be problematic. Even to have a scheme to only target one sector. Even though there is one for just batteries, the scheme is catching a large amount as it extends to various industries. Moreover, batteries also have a lot of profits in them; plastic has more to undergo more work, and it doesn’t contain the same amount of profit. I don’t think it’s feasible to go for an agricultural-only scheme.

7.

Do you think it should be included with some other scheme?

It can be included when the kind of plastics that are present are determined, but currently, the law here in Malta is on packaging.

8.

In the case of single-use plastic regulations, would fruit and vegetables sold in a container fall under this classification?

Single-use plastic containers are classified as single-use and unusable. The bag must be biodegradable and less than 15 microns or more than 50 microns to be used. They can be sold in bags, for example, but the bags must be biodegradable and less than 15 microns. The transparent strawberry box is not sideways, so it can still be used; one of the guidelines we give people is if you have a strawberry box, the box is not closed and can be put back in a bag because the bag to use the purpose of the bag is to avoid contamination.

Interviewee 3: ERA Illegal disposal compliance and enforcement—officer (Illegal management of waste).

Well to explain better this question, first one has to understand how we tackle cases and reports. We get reports from the public or entities through our website, telephone, or media channels, with the details provided, such as location, time, and type of incident. For example; someone is burning plastic, and there are bad fumes in the area. As compliance and enforcement officers, we gather as much info as possible to find the area. We take photos of the site and search for any evidence of the material which was burned. The owner or responsible person is confronted on the matter. They are ordered to clear the waste and warned that this carries hefty fines. The case remains active and monitored until the area is cleared. In cases with enough evidence of who incinerated the material and if the material is considered toxic, a fine is issued. Cases are also opened if ERA officers encounter the event.

2.

What do you mean when you say “considered toxic”?

Well, the legislation allows for organic/agricultural waste to be burnt, particularly 1 ton per day from the site of production. So, if a farmer is seen burning dry vegetation or crops, we do not have the remit to intervene. Anything other than that, for example: white goods, plastics, packaging waste, furniture, metal, we can intervene.

With farmers, we usually encounter a bit of both. For instance, farmers burn dry vegetation with some packaging waste from agricultural activities, or most commonly, plastic pipes. The burning of plastics is usually identified by dark plumes of smoke and heavy odors. In most cases, a fine is issued. Most of the time, the person is not aware that this is not permitted. Usually, it is a case-by-case basis, where the degree of waste, type, and if it was the first infringement is taken into consideration.

3.

What action do you take on the person responsible following the episode?

Following an episode, we stay in contact with the person; we give a time frame so that they clear the site from the burnt debris and any other waste. As I mentioned before, in some cases, we issue a fine, and if the person doesn’t comply, we issue an enforcement order. This carries daily fines until the area is remediated. To be honest, this is not as frequent, as most people comply.

4.

On average, how many cases related to farmers or agricultural sites do you encounter per year?

Concerning agricultural sites, we mostly received complaints related to the dumping of material. However, they turn out to be engineering works for soil replenishment. Cases related to waste management on agricultural sites would probably be around 10 to 20 cases per year. Usually, there is a seasonal spike, before and after summer where the crops are removed to make way for other seasonal crops.

Interviewee 4. Director at Ministry for Climate Change and Sustainable Development (MECP).

• Are there any policies, schemes, or any form of initiatives targeting agricultural plastic waste in any form?

There are agreements set in place at all levels, not in agriculture only. Such as, in transportation, culture, waste management, climate change, i.e., all these things. So, Malta at the EU level has signed the European Green Deal, which means we are agreeing to adopt it throughout the sectors. On the agricultural side, there is the farm-to-fork strategy, which is more based on food, arable farming, and types of farming practices, in essence, the whole industry; of course, this has side effects on consumables, such as plastic, so we can’t go into the farm-to-fork strategy without touching on the European Green Deal. In essence, they go hand in hand. As the director of sustainable development, we are not doing anything about this, because it is not within our remit. However, at the moment, I am doing a strategy on sustainable development that will cover up to 2050; of course, I will consult with the various ministries, and they consider various initiatives. Now, with regards to plastic waste and other materials, the farmer should know that he is not supposed to burn in tanks or any other area. They are supposed to take the waste to Wasteserv with the incentives register their vehicle and go as many times as one needs to the CA site. Now, how often this is done, I do not know, but the possibility is there. What is more effective are, for example, certain policies aimed to control pesticide use in agriculture. However, the policies address security rather than consumables. I do think that your research highlights an issue, as no one knows how much waste each farmer produces, for instance, plastic waste.

2.

Circling back to the green deal which you mentioned earlier, how can it help or impact the industry?

Degradable plastic is very expensive. Now, an option is to get aid from the government. To go green, even on a personal level. Disregarding farmers, it is very expensive, for instance, to install solar panels, buy an electric car, buy AAA + appliances. One can purchase these materials, but when you take all of these into consideration, you have a huge expense. This may save money in the long run because that’s the way it is, but for example, a normal white good can cost a normal amount of about 150 euros, while a AAA+ can cost about 250 euros. In essence, to go green, it’s expensive; this means that if we did not have subsidies on solar panels, very few people would opt for it. So, if we want to go green in the sector, we adopt something similar to the solar panels approach. I think we can go for a green approach for the farming sector. Just as the approach in installing solar panels in our community, we can do the same for the thing for the farming community and on different schemes.