Select Committee on Environment, Transport and Regional Affairs Fifth Report



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 same waste.

  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.

Juliana Goldenberg
Counsel

December 2000


 
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