Vital Strategies
The fund is organised exclusively for charitable, scientific and educational purposes: development, monitoring and evaluation of prevention programmes to improve public health worldwide.
ID: 244225040481-16
Lobbying Activity
Response to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
Thank you for the opportunity to comment on the EU's waste framework. Vital Strategies is a global public health organisation (with a European office in Paris) devoted to helping the world progress against the rising toll of diseases, including those associated with the built environment. Municipal waste management is, of course, an essential feature of human development, and as noted there remain significant gaps in the EU member states' capacity and infrastructure to properly manage solid and electronic waste, as well as waste-water to prevent population exposure to known hazards.
Section B (Objectives and policy options) correctly identifies the intended legislative objectives to decrease waste generation, improve waste separation to promote recycling, and increase the collection of waste oils. The options to support achieving those objectives are also well considered. We suggest, as a public health organization, that an enabling step for any EU member state to support these options should include a scientifically sound and transparent assessment of the business-as-usual health impacts and costs associated with waste management, and the potential benefits and savings associated with improved waste management under the legislative and policy scenarios. Current waste generation, collection and management is associated with the generation of air pollutant emissions which have, in some settings, significant impacts on ambient air quality, which in turn contribute to premature mortality and morbidity principally from respiratory and cardiovascular diseases. Globally, landfills contribute about 15% of total methane emissions. Waste burning in many developing and growing cities contributes substantially to the local burden of particulates. The generation of avoidable primary materials consumes vast amounts of energy which in turn results in pollutants emitted to air and waterways. The transportation of waste, especially by older and inefficient combustion engine vehicles, is also a major emitter in many cities.
Calculating the avoidable health impacts and costs to health systems and lost productivity would benefit local, national and regional efforts by helping to justify the necessary expenditures to improve waste management and recycling infrastructure and other costs. Failing to account for the significant reductions in these costs from avoidable chronic and infectious disease results in an overestimation of the net cost of policy actions, making them less likely to be fully adopted.
There are validated tools to estimate emissions from each of the stages of product generation, waste collection and waste management (or its absence) that can estimate total emissions of health-harming pollutants. In turn, there are epidemiologically validated tools to convert emissions into estimates of health harms. We suggest that the EU's Framework acknowledge the benefit of engaging, at the policy formation level, health ministries and other parts of countries' public health systems to support these efforts. Knowing the health costs and potential benefits from actions also helps mobilise public support, as public surveys routinely demonstrate that public support for climate and environmental actions is increased when immediate health benefits are described.
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