SUPPLEMENTARY MEMORANDUM BY DU PONT (UK)
LTD (DSW 04 (a))
On 21 November I was examined by the Sub-Committee
in connection with the above Inquiry. During my examination, I
agreed to provide further information to the Sub-Committee on
DuPont's views of the PRN regime.
In summary, we have found that the annual calculations
required in connection with the PRN regime are administratively
efficient when compared with the declarations required by other
regimes. For instance, in Germany we must make quarterly declarations
in relation to each type of waste material to the appropriate
recycling/recovery organisation (this requires approximately one
third of the time of a full time employee).
However, in our opinion the PRN system does
not give the end user (ie our customers) sufficient control of
the process even though the end user remains responsible for the
actual disposal of the waste. This leads to the situation where
both DuPont and the end user may purchase PRNs in respect of the
It also leads to the risk that DuPont will continue
to be liable for inadequately managed waste disposal despite purchasing
PRNs because we cannot control exactly what happens to our own
waste (ie our waste may be disposed in an illegal way (dumped
in a river, exported to E. Europe/Africa) by an end user or waste
management company without our knowledge).
In Germany, as a waste producer we actually
have a contract with each of the relevant waste reprocessors.
Therefore, we know who they are, where their collection points
are and can feel reassured that they are managing our waste adequately
by having their activities audited by the Chemical Industry Association.