Who is playing Snow White in pesticide’s waste package industry?

Recently I started to go through the correspondence with my former General Manager from RIGK and I found another piece of evidence in RIGK’s saga to cheat AIPROM clients. I choose to publish one of his messages from the end of 2011 just because I have to sustain an official position regarding how decisions were done in this company and to defend myself in front of RIGK allegations. I’m not so proud now about having too much advices and following his orders but I have to live with this and with a lot of other emails. After this example, please enjoy a new concept for German waste management ethic and accuracy: “Hi to all, 
Yesterday I received the last declaration from AIPROM members. Hard figures: Total market: 1202,1 tons
 Total plastic: 702,6 tons (90.43% HDPE; 9,57% PET) Total paper: 491,8 tons
 Total metal: 7,6 tons Based on the weighting notes, SCAPA collected: Total Quantity: 670 tons (55% from total) divided as: Plastic: 534,6 tons (76,1% from total)
 Paper: 135,6 tons ( 27,6 % from total ) 
Metal: 0,4 tons (5,5 % from total) Other +/- 20 tons on the road will be not included in 2011, hopefully will be accepted in 2012. The unbalanced percentage between Plastic (76,1%) and Paper (27,6%) is mainly the result of the decision took by association to aloud the incinerator to decide the quantity for plastic and paper in what were the mixed transport. Before to announce this numbers to AIPROM, I have to ask if: 1 – you agree that RIGK to change a number of annexes to re-balance the percentage before the report to AIPROM 2 – we deliver this results to Andrei, Ana, Carmen in order to fix the problem, then inform the companies
 3 – we announce like it is now. (…)” send on 08.12.2011 at 07:12 by Cornel Brad Markus Dambeck Geschäftsführer – RIGK GmbH : answer send on 8th Dec 2011,h 09:00: “Hi to all, Let me say so:
 It is nice that the market increase. Then we have the possibility to collect more!
 But coming back to your proposals. If you think that Position 1 is not a problem and easy to do and to explain without creating concerns I am fully agree with your position. But then we have to have a clear figure of what we will announce on position 1.  Please discuss this with the team in Romania today. I am going with all decision you make” I appreciated again the flexibility of my boss regarding the transformation of the waste materials but to decide I preferred to spoke not with RIGK team but with AIPROM representatives.  SCAPA  kept the results as they were written in documents and we planned to see in following years what are the reasons for this situation. Of course the situation did not repeat because the plastic from 2011 was very “heavy”. In the beginning of 2011, AIPROM audited all the collection documents from the previous years and found a lack of official documents regarding the waste transports,  a lot of official documents filled with information that describes other waste than SCAPA packages and a lack of information on other transport forms and some tones without weight notes. After this discovery, RIGK had to fulfil the complete documentations and to announce each transport to AIPROM. With this occasion I found that I forgot having a 76,1% recovery rate for SCAPA plastic. I think RIGK broke in that year the Romanian record in plastic collection! A lot of team trainings for RIGK performances! From EPRO European Association of Plastic Recycling site ( http://www.epro-plasticsrecycling.org )  I found that “RIGK gmbh is developing, organising and executing recovery schemes for plastic packaging and agricultural plastics from trade, industries and farmers. All packaging and films recovered through RIGK are controlled and safely and sustainably conveyed to a material or energy recovery”. I put one more doubt on my list. How the German Executive Manager of RIGK srl and RIGK gmbh managed the 2012 final waste declaration to Romanian National Environmental Agency? Still to come.

A German recipe to improve a pesticide’s packages collection scheme

Facts: August to November 2011, Mr. Dambeck initiated and controlled a method to introduce in SCAPA regular waste of plastic coming from the municipal waste collectors. Using this method, my German superior planned to cheat RIGK clients and AIPROM members by selling them other plastic than their packages that supposed to be collected by SCAPA. Mr. Dambeck is the General Manager of RIGK gmbh and RIGK srl, SCAPA is the Romanian Pesticides Packages Recovery System owned by AIPROM, the Romanian Crop Protection Industry Association.

In November 2011, Mr. Dambeck approved on an email the financial terms for this method. The deal supposed to provide a margin of 200-250%, representing the difference from the price of the acquisition for waste and the price that AIPROM members were paying to RIGK the SCAPA collection services, but mainly to help RIGK to reach its collection targets.

But my German chief avoid in his planning one important detail, something specific to the Romanian system: on all SCAPA recovery documents RIGK srl has to have Romanian farmers or agricultural companies as waste generators, not documents done with recyclers or waste traders as generators or providers.

I’m still asking my self if this proposal from my German colleagues is or was applied by any time in Germany.  It is  another personal Big Doubt about ECPA’s reports on “Hungry for change?” campaign, regarding the waste collection results as long as they are including Romanian and German data, as I will explain bellow.

Stepping a little back in time when RIGK srl was about to renegotiating the contracts with AIPROM members. End of 2010 and beginning of 2011, after negotiations with AIPROM Mr. Markus Dambeck accepted a severe cut for SCAPA collection price, a fixed price for next 4 years, an objective set at 67% for the recovery rate in 2014. Beside all that, RIGK srl had to invest in five years in logistics around half of the 2010’s turnover and yearly to spend tens of thousand Euros on SCAPA communication. Above all, RIGK srl had to reach the target year-by-year, otherwise any member, without any further notice might end the contracts. Less money for our services, more quantities as objectives, a lot of risks to keep a sudden death contract alive.

This deal was in my opinion unsustainable, mainly considering the Romanian farmers appetite to respect the environmental legislation for pesticide waste. RIGK srl collected until 2010 almost everything what was available to “eco” farmers, including some of the “historical” pesticides packages together with other non-SCAPA materials as fertilizers and seeds bags. For me it looks like living on the edge, but for my General Manager was very optimistic. And he was full of surprises too.

January 2011, in the same time with AIPROM negotiation, Mr. Dambeck contacted and started to negotiate a trading contract for recycling materials with a Swiss citizen having a Romanian residency and businesses in recycling industry.

In April 2011 the contract was sign between RIGK srl and a trading company registered in Romania and owned by the Swiss partner. This Swiss had to find for RIGK srl plastic waste to be trade through his company or to be commissioned for RIGK srl would do the trade based on his hints.

May 2011, contracts with AIPROM were signed. At that time RIGK srl was not even authorized as waste collector even if we run SCAPA for 3 years already. For the authorization RIGK had a August 2011 as deadline.

July-August 2011, a lot of searches and researches done by the Swiss trader, no one of his proposals were sufficiently good in terms of price and quality for our team in Germany. RIGK srl is authorized as waste collector.

August 2011, after a 2 day visit to a municipal waste collector in South West Romania, Mr. Dambeck brought his secret plan on the table and asked me in a conversation if I would participate in the scheme to introduce non-SCAPA materials in SCAPA collection. I refused.

July-November- the Swiss is still scouting for us, under the remotely but careful surveillance of Mr. Alexandra Nitu, another RIGK gmbh employee.

October – November 2011- we came closer and closer to the end of the year with an important deficit comparing with our plan: RIGK collected at 15th of September only 350 tons and the plan for 2011was 650 tons.

So, starting with October, the German team was activated under the pressure of time, in case we did not reach the objective the business might be closed by AIPROM members. Mr. Dambeck and Mr. Heil, who was PAMIRA manager and responsible for RIGK Romania collection activities, were both involved in a correspondence with me to set up how much and with what cost RIGK srl will introduce in SCAPA scheme plastic materials with other provenience that AIPROM contracts specified.

In November 2011, Mr. Heil announced me by email that he checked with Mr. Dambeck and I am right to decline their proposal to introduce in SCAPA quantities coming from the Swiss trader. What other solution RIGK srl had?

RIGK srl did not trade any waste quantities with the Swiss trader or other waste traders until December 2012, when I was dismissed.

Between January – August 2011 RIGK srl collected 350 tons of material from 663 collection points/farmers. Between September to 15th of December 2011, RIGK srl collected 250 tons of material from 371 collection points. On 15th of December 2011 RIGK srl declare to its SCAPA clients a collection of 670 tons, with a 55% recovery rate. From the total quantity reported to our clients, 70 tons were collected in the previous year, in 2010.

Was this a plan designed as a Romanian experiment or is a German recipe? cintar

Between 2008 and 2012, as long as I was directly involved in SCAPA development and in direct contact with RIGK gmbh and RIGK srl, few important differences and similarities between SCAPA and PAMIRA as pesticides packages collection schemes were revealed by me. Differences were:

  1. SCAPA made collection in around 70 Collection Centers but mainly directly from farms. PAMIRA collected their packages only at few hundred collection centers but not directly from farmers.
  1. SCAPA organized the collection campaigns at Collection Centers owned by pesticide wholesalers, part of the industry stakeholders, most of them being AIPROM members. At this SCAOA Collection Centers there were no other waste/packages than pesticide packages. The owners were focused on selling pesticides and not to collect waste. PAMIRA was organizing their collection centers mainly into a selected net of general/municipal collector’s warehouses, where other waste materials is still very available.
  1. SCAPA operator, RIGK srl, is a profit company, PAMIRA operator, RIGK gmbh, is a non-profit company.

Similarities were:

  1. SCAPA and PAMIRA prices for collected material were 3-5 times bigger than the similar type of material collected by a regular waste collector from a regular market. The difference might be explained partially with a cost of special inspection, special communication, special clients, etc.…
  2. SCAPA and PAMIRA had the same management and decision maker.
  3. Both SCAPA and PAMIRA operators were focused on profit.
  4. Collectors from both countries were very happy with RIGK team.

End of FACTS, now is only my personal opinion transformed in a personal concern. It is a personal opinion of a journalist, former manager and a free public speaker: For me it seems that is a big business opportunity and an easy to be done profit by redirecting some plastic from municipal waste into the pesticide collection waste stream. If this material is shredded is easy to hidden the provenience, easy to be transported and (surprise!) easy to be recycled. It might be a good business opportunity both for the PAMIRA’s collectors that are handling cheap municipal waste and for RIGK gmbh as the PAMIRA operator. At the end of the year everybody is happy: the industry, they are proud about astonishing results, the white-collar garbage men reaching their targets and bonuses and the dirty waste material collectors are having a better price for their waste, right at their gate.

A similar situation might be found in Poland, where Remondis is operating the pesticide collection system in parallel with other collection streams, so the precise control of the materials was impossible as long as I was in this business with direct information. And this approach is very probable in many European countries as long nobody from clients (associations of pesticides producers) and authorities are not checking the waste stream and the people that are managing the garbage are having the same attitude like the one I described above. Who wants to dig into dirt?

As I said, I’m still asking my self if the proposal from my German colleagues is applied by any time in Germany. It is  another personal Big Doubt about ECPA’s reports on “Hungry for change?” campaign, regarding the waste collection results as long as they are including Romanian and German data.

I presume those European Crop Protection Association results are wrong because, in this case is more true than any other situation, a basic statistic’s rule says: “Garbage in, garbage out”.

The Spanish case

SIGFITO, Spain, 2010. Recycling 98,7% from the recovered plastic pesticides packages classified as hazardous waste

Sigfito was the only solution for pesticides package recovery in Spain since 2002 to 2011. Sigfito’s shareholders are the Pesticide Industry Association representing about 100% of the market,  spanish pesticides distributors / wholesalers and spanish farmers associations.

In 2010, in Spain, Sigfito members sent on the market about 4300 tons of plastic packages, Sigfito collected 57,5% representing about 2.470 tons of plastic. Sigfito send to recycling 98,7% from this collected plastic, about 2.440 tons. This informations were available at ECPA headquarter in 2011.

The classification of a properly rinsed empty pesticide container in Spain was a hazardous waste, as long as until end of 2011. Collection points were doing storage and the first selection and then the materials are sending to a recycler, are landfilled or being incinerated.

Sigfito is the Spanish version of SCAPA, both of them being part of Collection Management Systems group activating in European Crop Protection Association- ECPA.

Sigfito management are controlling the information about the final waste dealer, but they cannot control the final produce done with this Spanish plastic.

ECPA is announcing a “Recovery and Recycling Success” at European level on their site and Mr. Jean-Charles Bocquet, Director General of European Crop Protection Association (ECPA) says “Plastic waste is an environmental issue that concerns us all. Recycling should be everybody’s responsibility, whether you run a household, have a restaurant or work for a big business”.

I’m also concerned when I will travel to Spain to drink water from a plastic bottle, hoping that someone doesn’t export too much plastic with a pesticide touch inside.

How is today Spain regarding the pesticide packages classification and recycling? Have no clue. What I know is that we get small portions of true.

A German report

In case someone believes that nobody from Germany knew what happened with RIGK srl collection for SCAPA, please let me bring to you a selection from an activity report done by a young German colleague.

A.B. is the author of an extended report of RIGK srl activity done after he was present for almost 5 months in Romania. He worked together with RIGK srl team in all departments of the office; he visited together with SCAPA inspectors all the collection areas and was travelling several times with me in Romania, in Resita and other collection sites. He was paid by RIGK gmbh and his report was send by email to all German and Romanian RIGK employees connected with SCAPA decisions.

As you will see, RIGK gmbh or RIGK srl team members took no decisions to eliminate from SCAPA system the non-SCAPA materials, at least not until december 2012.

A.B home address is 40 meters away to our General Manager house, in a small clean village of Germany, so I expect they had an extra little chat about Romania in case there was no time for reading an exhaustive report.

The text is my personal sellection focusing on subjects related to what I considered important for this blog.

”’ Time of internship:
 01.10.2011 – 18.03.2012 (without the time around Christmas and New Year as well as the time from 15.02.2012 – 29.02.2012) (…)

Transboundary Transportation:

Since the circumstances did not allow an immediate transport of SCAPA-material to Germany, this aim has been reached throughout the collaboration with Lineo Design and Multiport. In the beginning there did not exist a warehouse to collect a sufficient amount of material for transportation to Germany. The approval from AIPROM for recycling was missing, too. The prepared disposition for transportation is not used since the transportation from Romania to Germany is done by Multiport. (…)

Recycling of SCAPA-material:

As well as the topic above, this aim has been reached by the collaboration of RIGK with Lineo Design and Multiport. Recycling in Romania (Buzau) was not possible before (EVOH-layer), but could be possible in the future. With the first transport to Germany the sufficient quality of the material for recycling should be clear. (…)

Big Bags

Collected Big Bags are put on the SCAPA-system. Problem: Amount is quite high and could influence the total collected amount when not further collected. The famers rely on the collection of the Big Bags by RIGK. Multiport does not recycle Big Bags, so they still have to be incinerated. A new system could bring new revenues through the collection and sale of Big Bags. (…)

Collection of big bags in the collection amount of the SCAPA-System/anticipated collection amount in 2012:

According to the budget 2012, 780 tons of material in the SCAPA system will be collected. That would be an additional amount of about 16%. Without the collection of big bags, this amount is unlikely to be. However, it is assumed that AIPROM could notice by the inspection of the amounts collected / area and the comparison to sold products. That would endanger to the contract with AIPROM. Furthermore RIGK could take advantage out of the trading of big bags. (…)

Classification of the material

The waiting strategy that was agreed with AIPROM was not successful. The new developments could lead to a classification of the SCAPA material as hazardous material, if the analysis of the SCAPA material fails or is not recognized, or if the industry refuses to deliver the data sheets for their products. This is of course the worst-case scenario and is unlikely to happen.(…)

Personally the internship gave me valuable insights into the business world and the area of environmentally correct disposal of waste material. The structure of RIGK Romania, allowed me to quickly gain practical experience in important areas of business making and I hope that I could improve my skills. For RIGK I hope to have brought the best possible performance.

A.B.

Köln, 26.04.2012″

photo credit: Radu Posa

Double or a single standard in analysing pesticide’s packages?

In 2010, when I stepped into RIGK Romania office as an Executive Manager I asked my new colleagues how do they organised the sampling procedure for analysing in 2008 and 2009.

One of the SCAPA inspectors, a RIGK srl employee, was very proud to tell me he washed every container into his home’s bathtub before bring them to the office.  We are speaking about pesticide’s containers. The others were more precautions in expressing their actions but in the end came that they just selected the best clean whole packages from the cleanest bag they inspect at one generator. They all send a number of 10-20 packages, different sizes from 0,5l to 5 l, by post , two times per year,  to RIGK office. The sample was send together with a minute singed by one of the representatives of the collection site.

AIPROM required to RIGK srl this analysis by contract to keep a non-hazardous classification for the pesticides packages and to use this analysis in the communication with authorities. The European Crop Protection Association agreed & certified laboratory was Institute Kuhlmann from Germany.  I worked for AIPROM and I knew that was a very sensible subject.

Still considering this an important subject,  I opened this discussion with my colleagues from RIKG Germany and with my direct boss.  I found a smart answer: a blink of an eye. Thing has to go forward. He took the best decision between any legal obligation (there is no legal obligation per se to do the analyses) and to respect the contract with AIPROM and ECPA guidelines. Things were going forward in his way.

In march 2012, the waste management legislation changed in Romania making mandatory for a generator to classify a waste based on an analyse bulletin done by and authorised laboratory. I asked my German colleagues if might be possible to have at RIGK Romania a small shredding machinery for SCAPA packages to prevent any delays in case of a Environmental Guard control at farms or SCAPA generators.  I received a negative answer from RIGK Germany. Last try for me to do make things clear until now.

Between 2008 and 2012, 2008 and 2009 under direct supervision of RIGK Germany manager and between 2010 and 2012  under his supervision and with my acceptance, RIGK’s inspectors  send samples of pesticides packages carefully selected from SCAPA stream to RIGK srl office, then RIGK srl office send all the quantities by post, to Institute Kuhlmann. We had to have beautiful analyses for SCAPA waste in front of our national authorities and at European level.

In case a hazardous classification is mandatory for pesticide collected packages, the collections systems are facing 2-3 times more transportation costs and a more slow collection pace because of the complicate procedure to authorise an ADR transport. Every cost has to be paid by the industry.

What says the European Crop Protection Association guideline for sampling? 

Source: “Sample collection of plastic material out of shredded plastic containers (Post Consumer Resins, PCR’s) for later analysis of pesticide residues – Erika Seidel, Bayer CropScience AG on behalf of Packaging and Transport Expert Group of European Crop Protection Association- 2006”:schema

  1. “Definitions

4.1.  Primary Sample 
The primary sample is the amount of a shredded material taken at one time in one sampling step at one and only place (sampling location / sampling point) of a means of transport or directly out of the shredder process (8 portions each 30 t out of 10 t). 
The amounts of a number of primary samples should be in the same size. 
Primary samples are taken at randomly selected shredding sites in a certain interval defined by the manager of the collection scheme.

4.2.  Cumulative Sample (Optional) 
The cumulative sample is a summarized sample based on a number of primary samples. A cumulative sample is prepared by combining and mixing of primary samples.

4.3.  Final Sample 
The final sample is prepared out of several cumulative or primary samples by combining and mixing. A final sample might be a representativeA subset of the whole amount of all primary or cumulative samples after efficient combining and well mixing. 
The final sample should be almost 5-times as large as for the later analytical procedure needed.

4.4. Laboratory Sample

The laboratory sample is a subset of the final sample (where appropriate primary sample) intended to be used for analysis in the analytical laboratory after appropriate grinding according to method description [references [1], [2]].

Each analysis includes two replicates.”

End of the quote

When between 2008 to 2012 had SCAPA in Romania 30 tons, or 10 tons of shredded materials? Maybe in RIGK warehouse in Resita. Any sample taken from there?

Considering all these, please let me have doubts too about the sampling procedure in Germany and in their results widely promoted by ECPA, and to ask my self if is any double or single standard in the way RIGK is sampling the waste in their collection systems.

Update: the Spanish case 

Not the Milky Way

Ambalaj SYNGENTA mincat de o vaca in Insula Mare a Brailei

One day I made a visit to a farm. I saw a cow eating a pesticide’s paper box. I felt angry mixed with sorrow. Angry because something like this might happened next to any farm, daily.  Sorrow for seeing that people not care too much. I tried to do my best with SCAPA but I realised I cannot change too much.  In pesticide container waste management, when I hear about the extended producers responsibility I still feel Angry.  This industry cares about public image and I believe they will change their attitude searching for the truth not in meeting rooms but at farms and at their waste collectors.  So, I’m ready to change this Angry into Action. If you feel so, join and spread the word of Angry4Change with love for environment. Cornel Brad