SAFETY FEATURES FIXING FOR THE FUTURE: RIGHT TO REPAIR - COMPOSTABILITY GUIDANCE - WasteMINZ
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OFFICIAL MAGAZINE OF THE WASTE MANAGEMENT INSTITUTE NZ
MARCH 2020 \ ISSUE 174 \ $ 9.00
FIXING FOR
THE FUTURE:
RIGHT TO
REPAIR
THE TRUTH
SAFETY ABOUT BIN
AUDITS
FEATURES
COMPOSTABILITY
GUIDANCE
BEHAVIOUR CHANGE/WASTE DISPOSAL LEVY SUBMISSIONS
WASTEMINZ MEMBERS
P L ATIN U M S ILVER
ADSTAFF PERSONNEL
adstaff.co.nz
AUCKLAND COUNCIL
AURECON NZ
aucklandcouncil.govt.nz
aurecongroup.com
CIVIC CONTRACTORS
civcon.co.nz
GO L D
COCO-COLA AMATIL
ccamatil.co.nz
3R GROUP
FONTERRA
3R.co.nz
fonterra.com
FOODSTUFFS NZ
EARTHCARE ENVIRONMENTAL foodstuffsnz.co.nz
earthcarenz.co.nz GEOFABRICS NZ
geofabrics.co.nz
MANCO
ENVIRONZ
manco.co.nz
environz.co.nz
NZ SAFETY BLACKWOODS
nzsafetyblackwoods.co.nz
O-I NEW ZEALAND OJI FIBRE SOLUTIONS
o-i.com ojifs.com
OMARUNUI LANDFILL
hastingsdc.govt.nz
MINISTRY FOR THE ENVIRONMENT
mfe.govt.nz PATTLE DELAMORE PARTNERS
pdp.co.nz
PLASBACK
SMART ENVIRONMENTAL plasback.co.nz
smartenvironmental.co.nz PROGRESSIVE ENTERPRISES
progressive.co.nz
SCION RESEARCH
SULO
scionresearch.com
sulo.co.nz
SIMS RECYCLING SOLUTIONS
apac.simsrecycling.com
TONKIN + TAYLOR STANTEC
tonkin.co.nz mwhglobal.co.nz
THE PACKAGING FORUM
packagingforum.org.nz
VISY RECYCLING NZ
visy.co.nz WASTENET SOUTHLAND
wastenet.org.nz
WSP OPUS
WASTE MANAGEMENT NZ wsp-opus.co.nz
wastemanagement.co.nz
ON THE COVER CLEANING UP
NZ’S E-WASTE LEGISLATION
CHIEF EXECUTIVE
Janine Brinsdon \ +64 9 476 7172
janine@wasteminz.org.nz
SECTOR PROJECTS MANAGER
Nic Quilty \ +64 9 476 7167
nic@wasteminz.org.nz
12
SECTOR PROJECTS MANAGER
Jenny Marshall \ +64 9 476 7164
jenny@wasteminz.org.nz
CORPORATE SERVICES MANAGER
CJ Dooner \ +64 9 476 7162
cj@wasteminz.org.nz
COMMUNICATIONS MANAGER
Jill Marshall \ +64 22 697 1267
jill@wasteminz.org.nz
SUSTAINABILIT Y ADVISOR
IN THIS ISSUE
Sarah Pritchett \ +64 21 0825 4606
sarahp@wasteminz.org.nz
12
DESIGN, REVOLVE
Leanne Lassman \ +64 21 267 3885 HOW TO TACKLE OUR MOUNTING 26
leanne@electrichedgehog.co.nz E-WASTE PROBLEM
Right to Repair legislation aims
T +64 9 476 7162
PO Box 305426, Triton Plaza
to extend electricals’ lifespan 34
North Shore 0757 to reduce e-waste. Our Product WASTE DISPOSAL LEVY CHANGES
Unit 2, 5 Orbit Drive, Rosedale 0632 Stewardship Sector Group As the consultation over
New Zealand explains what it means for NZ. proposed changes to the Waste
16
wasteminz.org.nz Disposal Levy begins, WasteMINZ
members have their say.
WasteMINZ is the leading professional THREE KEY SAFETY FEATURES
body for waste management, resource
recovery and contaminated land
Terre Nicholson, Danny McClure 38
and Hugh Cherrill offer three sector WHEN DID ZERO WASTE
management in New Zealand. We deliver
groups’ perspectives on critical
value to our members through the BECOME ZERO PLASTIC?
shaping and sharing of policy and the health and safety matters.
Lisa Eve makes a plea for more
development of industry good practice.
WasteMINZ publishes revolve magazine
four times a year. It plays a vital role
26 understanding about plastics
as more New Zealanders strive
BEHIND THE SCENES AT THE AUDIT for Zero Waste goals.
in ensuring our members are up-
to-date with the latest in industry
The dirty details of researching
news, policy and legislative changes the nation’s recycling habits for
as well as innovations and advances. The Truth About Plastics Recycling
revolve magazine is a forum for positive report, described by Sunshine Yates. REGULARS
sector debate and discussion. The 02 MEMBERS
articles contained in revolve do not
necessarily represent the views of
32 04 FROM JANINE'S DESK
WasteMINZ or the WasteMINZ Board. COMPOSTABILITY: A SOLUTION 05 YOUR BOARD
TO THE CONFUSION 06 SECTOR GROUPS
As greenwashing of products and 11 MOVERS & SHAKERS
packaging increases, WasteMINZ
35 RESEARCH UPDATE
stepped in to provide clear
ISSN 2324-5417 (Print)
guidance for consumers and
36 FROM THE REGIONS
ISSN 2324-5425 (Online)
commerce. The Organic Materials
Sector Group explains.
20
Janine Brinsdon
Chief Executive, WasteMINZ
janine@wasteminz.org.nz
Talk to me +64 9 476 7172
FROM JANINE'S DESK
Welcome to the first issue of Sword and Sweden’s waste-
revolve for 2020, which ushers to-energy programmes, to the
in a new year, a new decade, increasing momentum gathering
and a fresh opportunity for around community and consumer
us to look to the future across initiatives about climate change
the waste management and and the wellbeing of the planet.
resource recovery landscape. In New Zealand, WasteMINZ will
January opened with a flurry be at the forefront of legislative
of activity for WasteMINZ, with a changes that affect not just our
series of workshops and webinars industry but our families and futures
rolled out in conjunction with — the whole of NZ Inc. Updates
the Ministry for the Environment to the Basel Convention, Right
to support members in their to Repair legislation, the Waste
responses to the Waste Disposal Disposal Levy, safety in lithium
Levy proposals. Four sector groups battery disposal, government
submitted group consultation policy around packaging including
documents, and we hope many of the proposed container deposit
IN OUR NEXT ISSUE you took the opportunity to voice scheme and zero waste activities
your opinions in this process of — all will feature prominently
Providing leadership and significant change and impact. in our programme this year.
cohesion through the Then, at the end of January, we We will not, of course, neglect
recently released National launched The Truth about Plastics the sector-specific concerns and
Strategy to Manage Emerging
Recycling — a report based on the questions that you respond to so
Contaminants. Louis Tremblay
intensive research carried out by ably in your sector group steering
and Graham Sevicke-Jones
the TAO Forum into the country’s committees and working groups.
tell all.
recycling habits. Aotearoa New This work is core to our mutual
Jennifer Elliott highlights Zealand sat up and listened with success and we will be shining
the importance, impact and the extensive media coverage even more focus on these groups.
challenges of collaboration generated by the report’s findings A busy year lies ahead for all of
between councils on joint — eye-opening to some, sobering us. Your board, WasteMINZ team
projects. and thought-provoking to all. and I are completely committed
This is just the entry point to ensuring that we represent and
If the waste levy increases,
for agreements, legislation reflect your interests and supporting
organic waste is a low hanging
and changes that will underpin you as members, sector groups and
fruit to divert from landfill.
Daniel Yallop asks what WasteMINZ' every action this year citizens of Aotearoa New Zealand.
investment and enablers and beyond. The world as a whole If you have any suggestions or
will be needed to ensure its is challenging the globe’s waste queries about this, please do get in
diversion is maximised. issues daily, from China’s National touch. I’m here to listen and to act.
4
HOW TO
Alice Grace
WasteMINZ Board
CONTACT
a.grace@morrisonlow.com YOUR BOARD
MEMBERS
YOUR BOARD
The latter months of 2019 saw Worker wellbeing is also key,
Wayne Plummer CHAIR
two new people appointed to to ensure our people go home safe wayne.plummer@environz.co.nz
the WasteMINZ board. I’m very and want to stay in our industry.
proud to be one of them, along This goes beyond health and
with my WasteMINZ colleague safety compliance to initiatives to
Alec McNeil of Marlborough manage worker fatigue and stress
District Council. It’s great to or promote open communication
be part of a strong governance around health and safety matters.
Parul Sood DEPUT Y CHAIR
group that represents a diverse Our industry is increasingly
parul.sood@aucklandcouncil.govt.nz
range of WasteMINZ members. in the spotlight, impacting the
For me, being appointed to work of all our sector groups.
the board is an opportunity to Ensuring that we all hear and are
give back to the industry I love. heard is critical, as was shown
Helping to address the challenges in the recent submissions by
our industry faces is important four of our sector groups to the
Darren Patterson
to me and a key part of being Waste Disposal Levy Consultation
darren@pattersonenvironmental.co.nz
on the WasteMINZ board. process. The programme of
For example, the waste industry webinars, meetings, workshops
has a role to play in reducing and information flow provided
carbon emissions by embedding by our WasteMINZ team and MfE
circular economy principles. We’ve to members was an excellent
seen recently, in the research example of working together,
Simonne Eldridge
and reports expanding our for the greater good of NZ Inc.
seldridge@tonkin.co.nz
understanding of how New Zealand I’m thrilled to be a part of
recycles plastic launched by the this vital organisation, and look
TAO Forum, that WasteMINZ is forward to meeting you all at
at the forefront of this work. our networking events and
Our influence and knowledge conference throughout the year.
will be brought to bear in similarly Mā te wā
Alec McNeil
significant areas as the coming year
alec.mcneil@marlborough.govt.nz
rolls by. This includes responding
to the government’s roll-out of
a priority product stewardship
scheme and supporting initiatives
to educate and inform the
public and manufacturers about
Alice Grace
composting, recycling and even
a.grace@morrisonlow.com
their purchasing patterns.
SECTOR
GROUPS
Nic Quilty Jenny Marshall Sarah Pritchett
BEHAVIOUR CHANGE Sector Projects Manager Sector Projects Manager Sustainability Advisor
nic@wasteminz.org.nz jenny@wasteminz.org.nz sarahp@wasteminz.org.nz
TAO FORUM
HEALTH + SAFET Y
PRODUCT STEWARDSHIP BEHAVIOUR
CONTAMINATED L AND MANAGEMENT CHANGE
DISPOSAL TO L AND
#COMPLEATING
ORGANIC MATERIALS
The annual Love Food Hate Waste
campaign in November focused
on eating all your food from root
to stem — aka #Compleating:
Five key foods to compleat —
potato skins and peels, broccoli ZERO WASTE
stalks, bread crusts, apple peels CLEANING
and all of the cauliflower Planning is well underway for
Target audience — 18 to 30 year Plastic Free July 2020, with a focus
olds, living independently and on Zero Waste Cleaning including:
learning new cooking skills How to use products like vinegar
Standout recipes — smashed and citrus peels for cleaning
potatoes and apple cider A recipe book with zero waste
vinegar from apple peels cleaning recipes (similar to the
Christmas media coverage Easy Choice Family Kai booklets)
— how to eat your Christmas Digital downloads and printed
leftovers and not buying too copies for all audiences
much in the first place! WasteMINZ members are
encouraged to consider running
some short workshops for their
staff or the public, promoting
zero waste cleaning ideas.
6
ORGANIC
MATERIALS
NEW STEERING COMMITTEE
Re-elected
Chris Purchas (Tonkin + Taylor)
Daniel O’Carroll (Living Earth)
Daniel Yallop (Morrison Low)
Dawn Smith (Scion)
New members
Joe Buist (Revital Group)
Karen Ashby (Global Composting
Solutions)
Lisa Hack (SLR Consulting)
Liz Stanway (Xtreme Zero Waste)
TAO FORUM Paul McGuire (Envirofert)
RETHINKING RUBBISH AND Richard Fine from Biopak has been
RECYCLING BIN AUDITS appointed as expert advisor to the
committee, to ensure members with
The Ministry for the Environment A second focus of the research
compostable packaging interests are
and the TAO Forum jointly funded was to determine what packaging
represented.
research into household rubbish design features are impeding the
and recycling behaviours via recyclability of plastic packaging ❤ Huge thanks to Joanne MacGregor,
bin audits of 897 rubbish and and what impact this is having. who stepped down in 2019, especially
recycling bins at eight council Along with the Associate Minister for all her work on Clopyralid.
locations around the country. for the Environment Eugenie Sage,
COMPOSTABLE PRODUCTS
This was New Zealand’s first ever WasteMINZ launched the first set
FACTSHEET
detailed dive into recycling bins, of results into the recyclability of
plastic packaging on Wednesday, The factsheet on material
to find out exactly what Kiwis are
29 January at Villa Maria in Auckland. composition of compostable products
recycling and to what extent we
are contaminating our recycling covering bio-based product claims
Read more in our report on page 26,
bins with non-recyclable items. has been reviewed by the Commerce
and pull out the data on page 29.
Commission, designed for maximum
impact and released at the end of
HEALTH AND SAFETY February 2020.
MAGAZINE COVERS
LOW ENTRY COLLECTION the Trainers delivery has been
VEHICLES reviewed by a working group and WasteMINZ is working with the NZ
is out for consultation now. Magazine Publishers Association on
A working group is reviewing the Low
a survey of their members to discern
Entry Collection Vehicles module from
FIRES CAUSED BY BATTERIES whether soft plastic or compostable
the Health and Safety guidelines: for
& COMPACTION plastic is the most suitable option
the solid waste and resource recovery
A regular discussion topic at Steering for magazine wrap. This survey
sector – parts one, two, three, four
Committee meetings is the challenge will provide information on home
and five, for consultation in March.
composting in New Zealand and
presented by the increasing number
KCTL TRAIN THE TRAINER enable the waste sector to get a better
of truck fires due to batteries
understanding of the number of Kiwis
The content of the Kerbside and compaction. See more in our
who have home composts which can
Collection Traffic Leader Train Research section on page 35.
take packaging.
MARCH 2020 \ WASTEMINZ.ORG.NZ \ 7
CONTAMINATED LAND MANAGEMENT
CLM STEERING COMMITTEE CONTAMINATED SITE
ELECTIONS OPERATIONS CERTIFICATE CL M
Elections are being held in March to The Working Group are now trialling
S T R E A M AT
be in place in late April. Do put your
CO N F E R E N CE
CSOP training content. Three pilot
hat in the ring when the Call for training sessions are due in March/ WasteMINZ received
Nominations is released; historically, April in Auckland, Wellington and fantastic feedback on
spaces have been hotly contested. the CLM stream at the
Christchurch. These will be open to
WasteMINZ’ conference,
WasteMINZ and ALGA members.
WASTE DISPOSAL LEVY especially:
SUBMISSION AND WEBSITE ASBESTOS WASTE ‘Growing your
RESOURCES contaminated land
In January 2019, WasteMINZ released
The CLM Sector Group’s submission risk assessment skills’
the Waste industry guidelines to
on the waste disposal levy is available workshop
manage the collection, receipt,
on wasteminz.org.nz. panel discussions
transport and disposal of asbestos
bioavailability sessions
Also available on WasteMINZ’ waste.
and bioavailability
website:
Due to national inconsistencies in workshop
How do I find a Suitably Qualified
approaches to the transportation
and Experienced Practitioner –
and landfilling of asbestos
SQEP?
contaminated soils, the guidelines
Why do I need a Suitably Qualified
do not include a section addressing
and Experienced Practitioner?
the management of disposal of soil
RESIDENTIAL LEAD containing low concentrations of
A big thank you to the
asbestos.
The Residential Lead Working working group members
Group is continuing to engage A working group has developed who made it all happen!
actively with key stakeholders. After a position statement, to initiate
We hope to see you again
contacting all the district health development of a consistent risk- in Rotorua in October.
boards around the country, the based approach to managing the
group is very excited to count a DHB disposal of soils containing low
representative among its numbers.
concentrations of asbestos, to go out
for consultation in March.
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8
A WASTED OPPORTUNITY
THE CASE FOR CHANGING THE WASTE LEVY
In New Zealand we discard
15.5 million
right
now PRODUCT
STEWARDSHIP
tonnes of waste each year we only recycle
3,200kg 28%
That’s
of this waste.
for every man, woman Is that good enough
PRIORITY PRODUCTS
for a CLEAN and
& child in the country! GREEN NATION?
WHY DOES 93 29
of Kiwis believe yet only
IT MATTER? %
waste & recycling
is an important
environmental issue,
%
29% think
we do a
good job!
The Product Stewardship Sector
IF WE EXPAND THE WASTE LEVY, BY 2025 WE CAN... Group is eagerly awaiting MfE’s
DELIVER DIVERT CREATE INCREASE announcement on its proposal for
$
500 3 up to
9,000 60%
our recycling
rate to
regulated product stewardship for six
MILLION MILLION
in net tonnes of jobs
benefit waste from and
become
priority products.
to the landfill
economy per annum a world
1 TYRES
per annum leader
$ 2 ELECTRICAL AND ELECTRONIC B.I.G. (BATTERY
READ THE REPORT at bit.ly/WastedOpportunity INDUSTRY GROUP)
PRODUCTS
B.I.G., an industry-led project to
3 AGRICHEMICALS AND THEIR
DISPOSAL TO LAND CONTAINERS
tackle large lithium-ion batteries,
was launched in November 2019 to:
With changes around the waste 4 REFRIGERANTS AND OTHER Match entrepreneurs with lithium-
disposal levy afoot, this is likely to be SYNTHETIC GREENHOUSE GASES
ion batteries that can no longer be
a very busy and interesting year in 5 FARM PLASTICS used in vehicles but have second-life
the disposal to land world.
6 PACKAGING potential;
WASTE DISPOSAL LEVY Trial sending end-of-life lithium-
With a WMF funded project initiated
The Steering Committee’s main ion batteries offshore to be
by Auckland and Marlborough
focus since mid-December has reprocessed;
District Councils, work has already
been developing the sector Produce health and safety
begun on the co-design of a
group’s submission on the waste guidelines for the safe storage and
container return scheme.
disposal levy. This was finalised in transportation of used lithium-ion
early February and is available on E-WASTE batteries;
WasteMINZ' website. Work with blockchain experts
The steering committee has
Everledger to ensure all parts
LANDFILL GAS COLLECTION established a Right to Repair working
of a battery’s journey to being
AND DESTRUCTION group as part of their e-waste focus.
reprocessed are transparent and
On behalf of the Steering Committee, There are plans to prepare a report
ethical.
WasteMINZ will be releasing a survey investigating whether Aotearoa
in March, on landfill gas collection and New Zealand needs Right to Repair See big.org.nz for more.
destruction. Watch out for this survey, legislation and if it does, what this
which is currently in development. might look like.
WASTE MANAGEMENT SOLUTIONS
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MARCH 2020 \ WASTEMINZ.ORG.NZ \
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9
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Shredding and chipping made easy: the Axtor Drum-roll: the Cribus
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Screening with a star: the Multistar The NEw MUStang: the Nemus
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SHREDDERS | TROMMEL SCREENS | STAR SCREENS | WINDROW TURNERS
www.komptech.comMOVERS & SHAKERS
JAMES BALDWIN LOUISE CAMPBELL LAURA MILLS
James Baldwin recently joined Louise started at Stratford District Previously an environmental scientist
Tauranga City Council as a senior Council in April 2019 and took over at Beca, Laura Mills has recently taken
the role of asset management over the role as contaminated land
waste contract specialist within the
coordinator in the Assets Team. Prior officer at Hamilton City Council. Laura
Sustainability and Waste Team.
to this position, she worked at Taranaki has over seven years’ experience
He has worked previously in contracts
District Health Board as the resident working in consultancies within
with Hydrotech, maintaining both
medical officer coordinator. both the contaminated land and
commercial and public infrastructure; Says Louise, “Part of my current role is geotechnical fields. She has worked
as sales manager with ChemWaste as the waste minimisation officer. This on numerous environmental and
(EnviroNZ), a nationwide leader in is such an enjoyable part of my job, contaminated land projects across
liquid and solid waste treatment, pushing through initiatives to reduce both New Zealand and Australia,
emergency response and disposal the waste going to landfill and working including preliminary desk-based
services, and as business developer with New Plymouth District Council assessments, intrusive ground
and South Taranaki District Council investigations, contaminated site
for a Chinese investor where he lead
for a regional approach to waste management/remediation and
an initiative to secure and build a
minimisation. Our district has some consenting projects under the
large automated manufacturing
great improvements underway for National Environmental Standards -
plant packaging water, from concept
diverting waste from landfill and big Soil. Laura is thrilled to be continuing
to production. plans for the long-term vision.” her contaminated land career in a
James can be contacted at Louise can be contacted at regulatory role and can be contacted
james.baldwin@tauranga.govt.nz lcampbell@stratford.govt.nz at laura.mills@hcc.govt.nz
WELCOME TO OUR NEW MEMBERS
GOLD SMALL BUSINESS Stephen Jones
Ministry for the Environment Divers Group Brandon Lee
SILVER Earthwise Group Nada Pirtek
Fonterra Environmental Protection Authority Richard Stevenson
NZ Safety Blackwoods Kāinga Ora Matthew Stewart
Land Information New Zealand Rebecca Turner
CORPORATE
Retail NZ Matthias Vest
Deluxe Bins
South Wairarapa District Council Abbie Watson
Eden Park
DCWISE Charitable Trust Nikki Withington
MRA Consulting
NZ Steel INDIVIDUAL STUDENT
SiteCare Allan Birch Chad Enns
The Warehouse Jill Ford Sumaraj Sumraj
Sarah Halliday Warren Fitzgerald
MARCH 2020 \ WASTEMINZ.ORG.NZ \ 11ON THE WAY TO FIXING THINGS The roads to Right to Repair legislation are opening up around the world — so what does it mean for New Zealand? The Product Stewardship Sector Group explains. 12
\\ P R O D U C T S T E WA R D S H I P S EC TO R G R O U P
To understand why we churn
through them so much faster,
Consumer NZ is undertaking a
project to gather information from
T
consumers about when and why
HE LINDESAYS were having their vacuum cleaners broke, and
an oven dilemma. Their how easy it was to repair them. Paul
10-year-old oven had will also take apart as many vacuum
stopped working and the cleaners as he can and ask questions
manufacturer’s call centre had of manufacturers to assess the
advised them to buy a new one, repairability of different vacuum
because its repairability wasn’t cleaners.
guaranteed and they would have to While the Consumer NZ study
pay the $100 callout regardless. But is not specifically looking for it, the
they were reluctant to buy a new study may highlight some examples
oven because of their plans to either of planned obsolescence. Since
renovate or sell the house. the 1930s, planned obsolescence
With advice favouring replacing has included a deliberate policy of
over repairing, it is not surprising encouraging replacement over repair
that a recent UK study reveals that by, for example, frequently changing
more than 44 million tonnes of the product design, not providing PAUL SMITH, HEAD
electronic and electrical waste was spare parts, or gluing batteries into OF TESTING AT
produced globally in 2017 — over six mobile phones so they can’t be CONSUMER NZ,
kilograms for every person on the replaced. It has become so normal BELIEVES THAT DUE
planet. This won’t necessarily all end that many consumers don’t seek to TO THE SIMPLICITY
up in landfill, especially as regulated
product stewardship develops in
repair broken products any more, but
automatically replace them.
OF THEIR DESIGN,
Aotearoa and overseas. Recognising both the inefficiency
VACUUM CLEANERS
However, can product and waste associated with this way SHOULD BE A ONCE-
stewardship switch the focus from of doing business, the international IN-A-DECADE
recycling to reduction and reuse? Or Right to Repair movement has been PURCHASE.
are other measures needed to tackle growing.
the underlying reasons for e-waste
becoming the world’s fastest-
A political hot potato
In the USA, Right to Repair has
growing waste stream?
become a political hot potato.
Shiny new things In 2019, Democrat presidential
On an annual basis we hear the hopefuls Bernie Sanders and
“news” that people have queued Elizabeth Warren indicated their
overnight to be the first to own support for federal Right to Repair
an over-hyped new model phone. legislation so that farmers can
Even well-known vacuum cleaner fix their own tractors. Currently,
companies regularly release new companies like John Deere build
models without much improvement software into their products that
on the old version. Yet Paul Smith, restrict repairs to authorised
Head of Testing at Consumer NZ, dealers only. These dealers may be
believes that due to the simplicity of expensive and a long distance from
their design, vacuum cleaners should the farm, causing farmers to resort
be a once-in-a-decade purchase. to software hacking and illegally-
sourced firmware to diagnose
problems and make repairs.
MARCH 2020 \ WASTEMINZ.ORG.NZ \ 13The first and only existing authorised ones. It would also be principles and requires that by 2021
Right to Repair legislation illegal for companies like Apple to appliance makers will:
(enacted in 2012) in the USA is the use software updates to disable • make spare parts and manuals
Massachusetts H4362 — an act devices repaired by non-authorised available to independent repair
protecting motor vehicle owners repair shops. shops for up to a decade, and
and small businesses in repairing Not surprisingly, a strong lobby • ensure parts must not require
motor vehicles. The Act requires group made up of tech giants such specific equipment to fix.
vehicle owners and independent as Apple, along with the Association The new rules apply to refrigerators,
repair facilities in Massachusetts of Home Appliance Manufacturers washing machines, dishwashers, and
to have access to the same vehicle (AHAM), has so far ensured that televisions and are aimed at making
diagnostic and repair information while 20 states have considered it easier to get items repaired by
that is available to authorised repair or are considering Digital Right to registered technicians, rather than
facilities. While this legislation was Repair legislation, none has been enabling consumers to do their own
only enacted in Massachusetts, enacted in any of these states. The repairs.
it resulted in a Memorandum of anti-Right to Repair lobbyists have
The EU directive could have
Understanding amongst the major raised concerns about consumer
both positive and negative impacts
car manufacturers to share repair safety, decreased security and
for Aotearoa New Zealand.
information with independent intellectual property rights. Right
Manufacturers with product lines
mechanics across the entire country. to Repair proponents argue that
that don’t comply with this directive
releasing diagnostic tools would
Updates on updates will still want to sell them — and
make it less likely that people will
If similar legislation targeting countries not bound by the directive
resort to illegal hacking to fix items.
devices and appliances was such as New Zealand are the perfect
introduced, manufacturers would Europe makes a start market to move them on to. The
be required to share diagnostic Towards the end of 2019, the upside? If spare parts are made
and repair information with European Union announced a available in Europe, they could be
independent repairers as well as directive along Right to Repair made available in New Zealand, too.
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MORE FREEPHONE 0508 HILL LAB (44 555 22)
www.hill-laboratories.comThe pathways for Right to outcomes at the top of the waste And this brings us to the point.
Repair in New Zealand hierarchy (that is, the prevention, While we may have to wait for Right
In New Zealand there are several reduction and reuse of 'waste’, not to Repair to become a reality, we
existing pieces of legislation that just recycling and safe disposal). don’t have to accept that something
could address the issue of repairability. cannot necessarily be repaired.
Such actions could include
Under the Consumer Guarantees Act Search for a manual online, see if
Right to Repair elements—such as
spare parts can be bought or find
retailers, manufacturers, importers requirements that manufacturers
a helpful repair worker, before
and distributors (including second-
make available diagnostic
resorting to replacing. If we all do
hand shops, etc) must have spare parts
information, tools and parts to this, that growing mountain of
available for a “reasonable” amount of
consumers and independent e-waste just may begin to shrink. R
time and a way to offer repairs. These
repairers—as these would increase
obligations can be avoided, however,
the reusability of electronic parts
by notifying the customer before
and effectively extend the life of
finalising the sale that spare parts and
repairs aren’t available. If this loophole electronics. Under a regulated
This article was prepared by the Right to
was tightened up, then we would be on product stewardship scheme, any Repair Working Group, which was established
under the Product Stewardship Sector Group.
our way to Right to Repair. electronics sold in New Zealand
Members include: Hannah Blumhardt (The
Another promising pathway would need to comply. Rubbish Trip and the NZPSC), Karen Driver
(Zero Waste Network and Envision), Peter
to Right to Repair is the current
A happy ending Thorne (Reclaim), Vicktoria Blake (Bay of
consideration of regulated product Plenty District Health Board), Paul Smith
Back at the Lindesay’s house, there (Consumer NZ) and Graeme Austin (School of
stewardship for e-waste, under the
Law, Te Herenga Waka – VUW).
is a happy ending to their oven
provisions of the Waste Minimisation
Act 2008. Early indications are dilemma. It turns out the bottom
that those designing the product element just needed replacing. A mere References
bit.ly/WEF-circular-vision
stewardship schemes will need $180 later (including the $100 callout
bit.ly/BBCEU-RTR
to prioritise actions that produce fee) their oven is working as before.
TO INFINITY
& BEYOND
Infinitely recyclable glass
For more visit: bit.ly/2J4rFP6
O-I New Zealand
www.recycleglass.co.nz +64 9 976 7127ES
T H E S A F E T Y F IL
r
d wellbeing of ou
The welfare an e
stomers and th
work teams, cu
is of paramou nt
general public
ross the whole
importance ac
. Here, three of
waste industry
ps demonstrate
our sector grou
oaches to
some key appr
ty: prevention,
health and safe
d planning
partnership an
ahead.
EXPOSURE
AND HEALTH
MONITORING
WHAT AND WHY?
16\\ C O N TA M I N AT E D L A N D M A N AG E M E N T S EC TO R G R O U P
Detection and prevention are key to safety. Terre Nicholson
describes best practice for contaminated land workers.
D
Regulatory Requirements
URING OUR presentation
CONTAMINATED Under the Health and Safety at Work
at the 2019 WasteMINZ
Conference, Dr. Dru
LAND WORKERS ARE Act 2015, employers who are acting
Marsh and I pointed out
ROUTINELY EXPOSED as Persons Conducting a Business
that contaminated land workers are TO A WIDE VARIETY or Undertaking (PCBUs) have a
routinely exposed to a wide variety OF HAZARDOUS responsibility to ensure a safe and
of hazardous substances at work and SUBSTANCES AT healthy workplace under the Health
that training and protection may be WORK AND THAT and Safety at Work (General Risk and
inadequate in New Zealand. TRAINING AND Workplace Management) Regulations
2016 (GRWM Regulations).
After our presentation, several
PROTECTION MAY In June 2018, WorkSafe issued a
people asked us what they should
do if they are worried about an
BE INADEQUATE IN clarification statement addressing
occupational exposure and for
NEW ZEALAND contaminated land and its
more information on employers’ relationship to the Health and Safety
responsibilities. • For the most part, women at Work (Hazardous Substances)
The most important thing (particularly pregnant women and Regulations 2017. In summary,
nursing mothers) have not been WorkSafe’s position is:
you can do is work with good
studied. There is some evidence • contaminated soil is not classified
health and safety practices,
that shift workers may be at as hazardous waste under
understand your potential risk,
higher risk than those working WorkSafe regulations
and keep informed. Here are a few
only a normal day shift (i.e., • the Resource Management Act
thoughts on the ways ahead.
between 8am and 5pm, Monday provides an existing framework
Exposure monitoring through Friday), and that female for managing contaminated soil
Exposure monitoring involves shift workers may be at even • the Hazardous Substances
collecting samples to evaluate higher risk. Regulations 2017 are not
concentrations of hazardous • The WELs evaluate exposure to applicable to contaminated land.
substances in the air. WorkSafe a single hazardous substance WorkSafe does acknowledge that
New Zealand has published and not to the wide array of PCBUs have a responsibility under
Workplace Exposure Limits (WELs) substances which contaminated the GRWM Regulations to:
for numerous hazardous substances. land workers may be exposed • provide adequate information,
While the WELs can serve as a to. Some synergistic effects, supervision, training, and
starting point to measure potential such as asbestos exposure and instruction to workers
risk to employees, they may not smoking, are widely studied and • ensure, so far as is reasonably
be adequately protective for some well known. However, for many practicable, that the workplace
workers because: combinations of hazardous allows persons to enter and exit
• The WELs are largely adopted substances, very few studies have and work without risk to their
from the US and UK and based on been conducted and there are health and safety
healthy males working 40 hours many known and unknowns. • provide personal protective
a week on day shift. The WELs are • The majority of the WELs also equipment and ensure the
a time-weighted average which only evaluate the inhalation equipment is suitable, maintained
provides for an average exposure pathway and do not address and worn correctly
over an 8-hour period. ingestion or dermal absorption. • manage risks to health and
MARCH 2020 \ WASTEMINZ.ORG.NZ \ 17safety associated with hazardous and what types of medical tests information about potential health
substances and ensure WELs are and health monitoring should be effects to help target appropriate
not exceeded conducted. health monitoring. The MSDS can
• undertake exposure monitoring An occupational medicine also provide information regarding
and/or health monitoring if practitioner is trained in evaluating exposure monitoring.
required. potential work-related health Alternatively, you can talk to
issues. They differ from a general your employer about instituting
In addition, where contaminated
practitioner because they specifically a health monitoring programme,
soil may “either be or contain a
look for links between health with baseline and routine physical
substance hazardous to health” the
and occupational exposures. An exams provided by an occupational
PCBU must:
occupational medicine practitioner medicine practitioner.
• identify hazards that could give
will ask detailed questions about Whatever route you take, stay
rise to reasonably foreseeable
your job – working conditions, informed, risk-aware and safe in all
risks to health and safety
hazards, noise, hazardous the work you undertake to minimise
• identify, implement, and review
substances, and ergonomics. and tackle occupational exposure.
control measures to manage risks
Based on your employment As the old adage says, prevention is
to health and safety.
conditions and history, the better than cure. R
For asbestos workers, health occupational medicine practitioner
monitoring is required by regulation can then request specific tests which
and approved codes of practice evaluate potential health effects
and there is a register in place to from your job. References
record exposures. However, there is bit.ly/CEBP-nightshift
no regulatory mandate for health What you can do bit.ly/WS-CLandHS
monitoring of contaminated land You can find occupational medicine bit.ly/worksafe-exposure-2
workers beyond the general duty of practitioners in New Zealand through bit.ly/worksafe-asbestos-reg
care clauses in WorkSafe regulations. a Google search. This should be your bit.ly/worksafe-1844-monitoring
first choice. But what if a specialist bit.ly/effects-on-liver
Health monitoring isn’t readily available or you prefer to bit.ly/OSHA-standards
According to the relevant WorkSafe work with your GP?
fact sheet, “Currently there is no The US Occupational Safety
work involving substances hazardous and Health Administration (OSHA)
to health that requires the health has published a guide on medical
monitoring of workers under the screening and surveillance
GRWM Regulations”, with the requirements. The OSHA guide lists
exception of asbestos. various hazardous substances and
It is important that you and your the recommended tests. This could
physician understand the toxicology provide a useful tool for discussing Terre Nicholson has over 30 years
associated with various hazardous health tests with your general of experience in contaminated land
substances. For example, exposure investigation, remediation, and management.
practitioner; however, the guide does
She holds a Bachelor of Science Degree
to vinyl chloride, polychlorinated not replace medical training and in Civil/Environmental Engineering and
biphenyls, and carbon tetrachloride judgement. a post-graduate Diploma of Hazardous
Materials Management. Terre is a Certified
are all known to cause liver damage. For people who are concerned
Environmental Practitioner with a Soil
However, any synergistic effects about past or present exposures to Contamination specialty, and has extensive
of being exposed to all three hazardous substances, a physical training and experience in risk assessment
and toxicology
substances, even at concentrations exam with an occupational medicine
She attended her first 40-hour HAZWOPER
below their relevant WELs is not practitioner is recommended. You training in 1990 and was a recognised trainer
well understood. An occupational can also read the Material Safety in the US. In her 11 years in New Zealand, Terre
medicine practitioner should have Data Sheet (MSDS) for the hazardous has participated in projects ranging from
preliminary site investigations (PSIs) of green
an understanding that all three substance(s). The MSDS are for fields sites to remediation of large heavily
substances can cause liver damage individual products, but can give you contaminated industrial sites.
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A MAN
WITH A
PLAN
Does your landfill have an asbestos management plan?
Hugh Cherrill asks the hard questions – and provides
some answers.
T
HE DANGERS of asbestos of detail required for site specific how risks from asbestos are to be
are well known, and in management of risk to workers once managed. The Regulations include
2016 the Health and asbestos waste arrives at the landfill a two-year transitional period for
Safety at Work (Asbestos) gate for disposal. preparation of an AMP to 4 April
Regulations came into force in New 2018. From this date all landfills
So what do the accepting asbestos for disposal (or
Zealand prohibiting most work
Regulations require? with previously disposed asbestos
involving asbestos. However, the
PCBUs must ensure that exposure
Regulations allow specific activities, waste that may pose a risk), should
of workers to airborne asbestos is
including the transportation and have had an AMP.
eliminated so far as is reasonably
disposal of asbestos waste, subject Who is responsible?
practicable (or minimised if not
to implementation of measures to reasonably practicable to eliminate) At a landfill, the duties under the
ensure safety. The Regulations apply and that the airborne contamination Regulations fall on more than one
to disposal of waste containing even standard for asbestos set in the PCBU. Typically there is a landfill
very low levels of asbestos. Regulations is not exceeded. operator, the landfill owner (often
There are a number of guidelines Transportation and disposal of different from the operator) and
that provide interpretation and advice asbestos and asbestos containing companies that deliver asbestos
on the application of the Regulations. material is permitted and is waste to the landfill. These PCBUs
They describe procedures for asbestos categorised as ‘asbestos-related must consult, coordinate and
removal from buildings, removal work’. The requirements for this cooperate to make sure their legal
of asbestos contaminated soil, type of work are set out in the duties are met and risks are properly
transportation of asbestos waste and Regulations. controlled. At a landfill, the PCBU
general requirements for disposal. For any site where asbestos is with the most control is the landfill
However, these guidance present, an Asbestos Management operator and they have the primary
documents do not provide the level Plan (AMP) is required that sets out responsibility to prepare an AMP. It
20is recommended that the operator • Unloading — to prevent release of
and owner develop the AMP, working asbestos fibres
GUIDANCE
together to ensure that all risks are • Asbestos contaminated soil DOCUMENTS
covered and roles and responsibilities — often large volumes, special
& THEIR FOCUS
defined. Requirements flowing from procedures may apply
the AMP need to be communicated to • PPE — what, where, when
Management and removal of
PCBUs delivering asbestos wastes and • Covering the waste — how, how
they need to incorporate them into asbestos. Approved Code of
much, how often
their own safe working procedures. • Contingency/emergency measures Practice, WorkSafe 2016 (the
and decontamination — dealing ACOP)
How are risks from
with spillages or release of
asbestos managed? Demolition of buildings and
asbestos fibres
The AMP sets out the procedures to
removal of asbestos.
• Airborne asbestos fibre
be followed to ensure that risk from
monitoring — what, where, when,
asbestos is controlled in accordance
follow-up actions New Zealand Guidelines for
with the Regulations. A typical AMP for
a landfill receiving asbestos containing Procedures for detailing incidents — Assessing and Managing
wastes is likely to include sections records and reporting. Asbestos in Soil, BRANZ, 2017
addressing the following topics:
Some key issues Investigation, management
• Information about the asbestos at
Unloading vs tipping
the site — what, where etc. and remediation of asbestos
Bagged, wrapped and containerised
• Decisions about the management contaminated soil. Guidance
asbestos waste should be unloaded
of asbestos risk and the reasons on working with asbestos
carefully from delivery vehicles to
for those decisions — safety and contaminated soil.
avoid damage to the containment
regulatory compliance focus
and possible release of asbestos fibres
• Roles and responsibilities — the
– not tipped. The exception to this is Waste industry guidelines
parties involved and what they do
bulk loads of asbestos contaminated to manage the collection,
• Training
soil for which special procedures are receipt, transport and
• Health monitoring
required. disposal of asbestos waste,
• Pre-approval procedures — waste
acceptance requirements Soil with low asbestos fibres WasteMINZ 2019
• Containment — wrapping etc. concentration
General guidance on the
• Receipt — procedures and A particular issue that arises with
inspections asbestos contaminated soil is deciding management of the collection,
• Dedicated disposal location — for how to handle soil containing very receipt, transport and disposal
example, fencing, signage low concentrations of asbestos fibres, of asbestos waste.
EHS Support New Zealand Ltd – Local Experts. Global Partners.
Services include:
• Contaminated land management – PSIs, DSIs, human health risk assessment, and remediation.
• Landfill gas and vapour investigations, assessment, and mitigation.
• Asbestos management – licensed assessors, surveyors, asbestos management plans, asbestos in soil.
• Environment, health and safety management support – resource consenting, auditing,
process/control development, strategic advice, and compliance.
• Spill and emergency response.
Meet the New Zealand Team
Dave Dangerfield • david.dangerfield@ehs-support.com • Tel: 0275 577 342
Hiram Garcia • hiram.garcia@ehs-support.com • Tel: 0221 050 085
Rebecca Cleghorn • rebecca.cleghorn@ehs-support.com • Tel: 021 518 420
Simon Hunt • simon.hunt@ehs-support.com • Tel: 021 402 997
Mike Mechaelis • mike.mechaelis@ehs-support.com • Tel: 021 399 451 MARCH 2020 \ WASTEMINZ.ORG.NZ \ 21something that WasteMINZ aims that soil is tested to confirm that work with asbestos waste is carried
to address in the Waste Industry it contains less than 0.001% w/w out, should wear PPE unless they are in
Guidelines to manage the collection, asbestos prior to acceptance. a vehicle fitted with a HEPA filter.
receipt, transport and disposal of Whatever the approach and
Further details on all these challenges
asbestos waste in 2020. controls a landfill decides upon,
can be found in a paper presented
The BRANZ guidelines identify the reasoning around decisions
at the 2019 WasteMINZ conference
a concentration of friable asbestos should be documented in the AMP
(Disposal of asbestos containing
or asbestos fines in soil of less than to demonstrate that the exposure to
wastes at landfill, Hugh Cherrill
0.001% w/w as being unlikely to asbestos fibres is being controlled in
and Natalie Pilcher), which is on
lead to unacceptable increased accordance with the requirements of
WasteMINZ’ website.
cancer risk from airborne asbestos the Regulations.
The overall message is clear,
fibres. BRANZ identify work with soil Asbestos waste cover however: if you don’t have your AMP
containing less than 0.001% w/w Asbestos waste must be covered in place already, it’s time to pull it
asbestos as lower risk work that they to prevent potential release of together now. R
designate ‘unlicensed asbestos work’. asbestos fibres. Cover soil is often
For ‘unlicensed asbestos work’, the placed on a daily basis, but this can
BRANZ guidelines indicate that no lead to inefficient use of void space
asbestos-specific PPE or respiratory where delivery of asbestos wastes is
protection is required and that infrequent. If wrapping/containment
handling such material essentially is intact, cover soil may not need to
requires only dampening. On this be placed immediately and at some
basis, some landfills handle this landfills the coverage interval is up
material as special waste (dampened) to a week. About 200mm to 300mm
without asbestos specific safety of daily/weekly soil cover is typically
measures and do not require it to be specified in the landfill AMPs.
disposed of in the site’s dedicated PPE
asbestos disposal area. The referenced guidance documents
However, the Regulations and are clear on asbestos-specific PPE
WorkSafe ACOP appear misaligned required. It is less clear who should Hugh Cherrill is a Principal Civil and
with the BRANZ guidelines, in that Environmental Engineer based in Tonkin
wear it and when. Work with risk of
+ Taylor's Wellington office. He has more
they are clear that this type of work release of asbestos fibres exceeding than 25 years of experience with landfill
is ‘asbestos-related work’ and so this trace levels should be confined to the engineering projects. His involvement in
such projects includes site selection studies,
approach can be difficult to align with dedicated asbestos disposal area. The concept design and consent applications
the requirements of the Regulations precautionary approach is that anyone through to detailed design, construction
contracts and landfill operation.
and ACOP. This approach also requires in the asbestos disposal area, when
GEOTECHNICAL | ENVIRONMENTAL | OBSERVATIONAL
22 26 Lon d on St reet, Hamilton \ hdgeo.co.nz\\ H E A LT H A N D S A F E T Y S EC TO R G R O U P
PRACTICAL
PARTNERSHIPS, JOINT
RESPONSIBILITY
Danny McClure describes the four Cs of critical risk management
in kerbside collections health and safety.
W
HEN IT COMES to Contract When a kerbside contract has been
kerbside operations Some of it is down to the contract. awarded or extended, all stakeholders
between a local body A Person Conducting a Business need to build, maintain, encourage
and a contractor, or Undertaking (PCBU), councils and and instil a positive relationship
there has always been that “divide” any other businesses engaging with within the service contract. This
about who is ultimately responsible is initially at the higher levels of
a contractor or contracted works/
for health and safety (H&S). management but is also highly
services have a joint, overlapping
applicable throughout both council
Previously, there has been responsibility to ensure the safety of
and the contractor’s businesses.
a perception from some that all workers, public and contractors
We would do this by:
councils dictate the method in when working onsite, in a public
• Showing respect and value for the
which collection contracts are space or out in the field undertaking
skills, experiences, creativity, and
applied and how the engagement these contacted works — or:
contributions of all members
process rolls out. This has changed “A person conducting a business or
• Adhering to leadership and
significantly in the last few years to undertaking (PCBU) must ensure,
decision-making guidelines
a process of positive engagement so far as is reasonably practicable,
• Embracing diversity
and a collaborative approach the health and safety of workers, • Listening to and acknowledging
to hazard identification, risk and that other persons are not put the feelings, concerns, opinions,
management and mitigation. at risk by its work. Risks that arise and ideas of others
The facts are that health and from work must be eliminated so • Constructive engagement and
safety is everyone’s responsibility. far as is reasonably practicable. If a introductions
So why is it important that council risk can’t be eliminated, it must be • Taking the time to understand
and contractors form a partnership minimised so far as is reasonably the challenges and motivations of
when dealing with health and safety? practicable” (WorkSafe NZ). each business.
MARCH 2020 \ WASTEMINZ.ORG.NZ \ 23In addition, providing a mandate the contracted service. At its best, it Primarily, private kerbside
for ownership for each individual’s underpins the collaboration we need contractors are motivated to
role within that service contract — to positively achieve all the required provide a service from which they
whether as a driver, runner, yardman outcomes safely, even to the point can financially benefit, allowing
or manager/council representative of assisting in preventing Serious them to invest in their staff,
— drives accountability and Injury or Fatality (SIF) events. assets, overall wellbeing and
responsibility for actions, assets, It also leads to effective longevity of their company, without
reporting and workmate wellbeing. reporting, establishing the compromising the safety of others.
checks and balances required Council’s motivation, I believe, is
Collaboration to run, manage and positively two tiered: consideration needs to
Workplace collaboration keeps
participate in kerbside service be applied to the contract owner or
everyone safe, initially from any
contracts. This makes it second contract team and their motivation
extra workload. The work should
nature for the teams who actively to achieve results, while not losing
be evenly distributed, and both
work with kerbside challenges sight of what the public are needing
council and contractor should
on a daily basis to keep health to ensure the essential kerbside
take the time and energy to assist
and safety “front of mind”. obligations and long terms plans/
everyone involved within their
The most effective tool in WMMP set by council are achieved
respective organisations and teams.
all reporting instances are the safely, as identified in the Health
Working in teams makes individuals and teams actually doing and Safety at Work Act 2015.
everyone feel collectively what they do well kerbside. These
The best and easiest way to
responsible and it also raises reporting initiatives add the most
achieve this is to collaboratively
motivational levels, leaving value at very little or no expense:
work with councils and their
nothing to chance. In turn, this • Near miss reporting — key part
relative stakeholders to understand
helps to develop the skills for of identifying issues before they
those required outcomes. In
positive interactions while leading occur
applying a structured and
to the desired outcomes and • Hazard ID and subsequent risk
collaborative cultural approach,
reinforcing positive reputations. review/mitigation
parties would need to:
• Wellbeing of staff/individuals/
Communication • Recognise and accept the need for
contractors — ensuring a positive
A very clear direction and partnership
culture and mindset where we
expectation of outcomes • Develop clarity and realism of
all feel we need to “look after our
requires clear, concise instruction purpose
mates”
and communication. In the • Structure reporting to suit needs;
• Asset and equipment reporting —
past, there have been minor • Ensure commitment and
tools that are fit for purpose.
breakdowns in these areas, ownership
leading to significant and negative Culture • Develop and maintain trust
reputational and H&S exposure, A key to ensuring and maximising • Create clear and robust
resulting in financial penalty or mutual results has to be partnership arrangements
an enforceable undertaking. understanding the culture of the • Monitor, measure and learn from
A recent example is a Northland respective businesses and the reporting systems; and
construction company who were outcomes each are seeking. • Always seek continual
ordered to pay reparations of For instance, though improvements within the
$151,578.21 to a worker who was empowering teams to be proactive partnership contract.
left permanently paralysed from and “speak up” about health and
the chest down after falling two
Conclusion
safety concerns is the collective
It’s not enough to own the contract.
metres and landing on his head. responsibility of both the council
All these components need to come
Incidents like this demonstrate contract owner and the kerbside
together to enable everyone involved
how good communication doesn’t contractor, culture could play
to have a better understanding
only encourage effective teamwork a significant part in preventing
of the overall operational and
and promote transparency within someone from opening up.
24You can also read
