Lina Goodman, Tyre Stewardship Australia CEO, speaks with Waste Management Review about its world-first foreign end market verification program that will significantly increase waste tyre supply chain visibility in local and international markets.
When Tyre Stewardship Australia (TSA) was formed in 2014, its initial guidelines called for market development activities to focus on early stage research and development.
One year later, TSA launched its key investment mechanism, the Tyre Stewardship Research Fund.
In an ever-evolving space, the fund has to date directed $4.9 million to 34 research and development projects.
As TSA’s goal is to reduce the environmental, health and safety impacts of the 56 million equivalent passenger units generated annually, it’s an agenda the voluntary product stewardship scheme does not take lightly.
With research and development into tyre-derived product well and truly proven, TSA needed to change tack, enhancing its strategic focus as it underwent Australian Competition and Consumer Commission reauthorisation.
Last year, it broadened the original guidelines of its Tyre Stewardship Scheme, allowing it to drive a more immediate consumption of Australian generated tyre-derived product.
In doing so, TSA launched a demonstration and infrastructure stream, which proved to revolutionise its existing remit through practical outcomes, approving new products consuming almost a million tyres per year.
The stream ensures TSA can support an array of sectors, including in roads, advanced manufacturing, civil infrastructure, rail, building construction and more.
It generated an additional $3.2 million in new sales for the Australian recycling market annually, but importantly led to critical sustainable outcomes.
One of these many projects was the announcement of a test of new mixes of crumb rubber asphalt on a 335-metre stretch of road in the South Australian City of Mitcham.
In another innovative initiative, the Victorian Department of Transport is now conducting the first large-scale crumb rubber asphalt trial on an arterial road, in a two-year trial with the Australian Road Research Board.
To support TSA’s next evolution, TSA also welcomed a new CEO in Lina Goodman, who brings extensive experience in delivering commercial and environmental outcomes.
Lina’s breadth of experience comes as a paradigm shift is occurring in the waste sector, with increased commitments from federal, state, territory and local governments to procure recycled materials, including in major road projects.
She joined TSA in January 2019 after a long career in sustainability including roles at VISY, Honeywell and TIC Group.
To that end, she tells Waste Management Review auditing and verifying downstream international venders is one of TSA’s current focuses.
“With a significant volume of Australian end-of-life tyres exported for processing in foreign end markets, verifying environmentally sustainable and ethical management of exported tyres is central to the integrity of the Tyre Stewardship Scheme,” Lina says.
In 2018/19, Australia produced 450,569 tonnes of tyre waste. Over this time, approximately 43 per cent of all end-of-life tyres were exported as either casings, tyre-derived fuel shred, baled whole, or off-the-road tyres exported for crumbing, with the largest portion being shred at 29 per cent.
Given the scale of exports and well-known consequences of unsustainable management, TSA has developed a world-first foreign end market verification program for end-of-life tyres.
Despite an international ban on whole baled tyres in the works, verifications of final destinations is paramount, as tyre products are still sent offshore for further processing.
“We are taking new steps and are a lot more agile, dynamic and creative about how we want to function in the industry and wider marketplace. I like to call it next generation TSA,” Lina says.
“Our aim is to support initiatives that bring together strong partnerships across the supply chain, crossing research institutions and industry partners, to demonstrate both the technical and financial viability of products.”
In 2019, TSA engaged third-party quality assurance company Intertek to develop a platform and process to audit downstream vendor behaviour. According to Lina, the program will verify sustainable outcomes, ensure exporting processor accountability and educate operators both domestically and offshore.
“Intertek audits the sites based on a set of criteria including modern slavery, occupational health and safety, technology and hub and spoke,” Lina says.
“In terms of technology, auditors assess whether the technology is fit for purpose, and with hub and spoke they ensure the material is being processed at the collection site and not transferred to other unverified locations.”
During the first round of audits, there were some issues to work through. One of these saw Intertek identify staff working inside buildings that were locked from the outside, which created a fire hazard.
“We also came across sites engaged in environmentally unsound practices, and some that wouldn’t allow our auditor to enter,” Lina says.
“In that instance, the auditor took photos around the perimeter of the site and spoke to people living and working in the area – it’s quite an investigative process.”
Under the verification program, for foreign end-markets to accept material from TSA accredited participants, they too require will TSA verification.
To receive verification, Lina says operators first run through an education program to understand TSA’s expectations. From there, operators conduct self-assessment questionnaires, providing photographs and procedural details.
“Intertek and TSA will then verify that information, and if we identify any red flags, we will send an auditor to the site,” Lina says.
“The whole idea is to ensure overseas operators are not causing any environmental or social harm. That’s the bottom line.”
According to Lina, TSA has recently conducted a number of audits in Malaysia and India, with many ticking all the relevant boxes.
“The program enables us to ensure the material is being recycled in an appropriate manner, and also guarantees that Australian recyclers are informed about where they are sending their material,” she says.
“We need greater overall visibility of the reverse supply chain of waste tyres. We can’t really be sure that materials are being appropriately managed if we don’t have them verified by a third-party organisation.”
In addition to the downstream verification process, Lina says TSA is enhancing its international relationships through associations with groups such as the International Rubber Study Group (IRSG).
The IRSG is an inter-governmental organisation comprising rubber producing and consuming stakeholders, with 36 member countries and over 100 members covering the entire natural and synthetic rubber value chain.
“The IRSG has traditionally worked within the new tyre and rubber segment of the market,” Lina says.
“However, they recently recognised the need to include sustainability and end-of-life tyres into their discourse.”
As part of the partnership, TSA is hoping to join the IRSG’s sustainability committee, which Lina says will help facilitate connections with international governments.
“Joining the IRSG will create a direct line to governments in places that currently receive our material, such as Cameroon and India,” Lina says.
To facilitate greater market transparency, TSA is also working on a new suitable outcomes indicator, which Lina says models the good, better and best of tyre recycling.
“One recycler is not the same as another recycler, there are various levels of measurable environmental outcomes,” she says.
Lina says TSA has begun identifying its participants against good, better and best outcomes, with recyclers judged on process, and retailers judged on their choice of recycler.
“We have thousands of consumers who visit our green tyres website and want to do the right thing for end-of-life tyres. They ask, who can I buy tyres from? Who provides sustainable outcomes?” Lina explains.
“We really need to shine a light on organisations that have invested locally and are making an effort to transform tyres into products for local use, and I think the sustainable outcomes indicator will help that.”
EXPORT BAN AND THE PSA
The recent Meeting of Environment Minister’s confirmed a phased approach timeline for the ban on waste exports, as announced by the Australian Council of Government’s (COAG) earlier this year.
All whole tyres, including baled tyres, will be banned from export by December 2021. While Lina says whole tyres represent only a small percentage of what is exported, TSA is supportive of government putting regulatory levers in place.
“Of the 223,000 tonnes of end-of-life tyres recovered in 2018/19, 84 per cent was exported and 16 per cent remained in Australia for use within local applications. Of the volume exported, 25 per cent was whole-baled tyres and 68 per cent was exported as shred,” she says.
“That said, the ban has led to increased conversation locally about investment in new facilities and upgrades, and because of the ban, the market conditions are now right.”
Lina adds however that for the ban to really change the state of end-of-life tyre processing, it needs to come hand in hand with a strengthened Product Stewardship Act.
“It’s wonderful to have the COAG statement, but we need the act reviewed to provide us with more opportunity for market development and to keep all tyre importers accountable for the products they bring into the country, not just a select few,” she says.
“We are a voluntary scheme – we have eight tyre importers now contributing to the levy and one automotive brand, but we really need all of them participating.”
While questions remain over the long-awaited Product Stewardship Act review’s outcomes, Lina says she is heartened by the progress made by TSA over the past 12 months.
“If the Product Stewardship Act review can address the issue of free riders, or as I have heard them to referred to as “environmental pirates”, we will have more funds to redirect to organisations that want to address end-of-life tyres commercially,” she says.
“That said, there is already a whole range of support programs in place. We are excited by the opportunities that will arise from the export ban and our market development strategy, which is already delivering significant outcomes. The next generation of TSA is looking bright.”