Better Practice Actions and Targets-29.08.13

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Better Practice Actions and Targets Suggested Actions and Goals for Signatories ACTION PLAN DEVELOPMENT

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APC

Transcript of Better Practice Actions and Targets-29.08.13

Page 1: Better Practice Actions and Targets-29.08.13

Better Practice Actions and Targets Suggested Actions and Goals for Signatories

ACTION PLAN DEVELOPMENT

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Better Practice: Suggested Actions and Goals for Signatories

The APC has prepared this list of suggested actions, targets and milestones in response to requests for additional resources to assist signatories in preparing their action plans. This list is neither comprehensive nor prescriptive, but is intended to give an indication of a range of measures which could be incorporated to address the APC performance goals and KPIs.

While each action may not be applicable to all industries, the range of options presented may give signatories an idea of the variety of actions they may choose to include. It is anticipated that signatories will refer to this document in preparing or reviewing their action plans as an indication of measures which could be considered appropriate under each KPI, and which might represent ‘better practice’ actions and targets.

We have added notes for some items to explain their relevance to signatories – this content should not be included in action plans. You can navigate actions and targets specific to KPIs you are developing by using the navigation links below (clicking the ‘HOME’ button at the top of each page will return you to this page): Design [Goal 1] KPI 1: Signatories with documented policies and procedures for evaluating and procuring packaging using the SPG of equivalent Recycling [Goal 2] KPI 3: Proportion of signatories with on-site recovery systems for recycling used packaging KPI 4: Proportion of signatories with a policy to buy products made from recycled packaging or materials Product Stewardship [Goal 3] KPI 6: Proportion of signatories that have formal processes for working with others to improve design and recycling of packaging KPI 7: Proportion of signatories demonstrating other product stewardship outcomes KPI 8: Reduction in the number of packaging items in litter

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Performance Goals and KPIs Actions Target Milestones Notes

1. Design – optimise packaging to achieve resource efficiency and reduce environmental impact

KPI 1: Signatories with documented policies and procedures for evaluating and procuring packaging using the SPGs or equivalent.

Signatories assessing 100% of new packaging and 50% of existing packaging against the guidelines.

Addressing this KPI requires two key features:

1. Incorporating the SPG into your organisation’s design or procurement process, ensuring packaging sustainability criteria are considered prior to new products being released into the market;

2. The scheduled assessment of existing packaging against the SPG.

Better plans will detail how the outcomes of these assessments will be incorporated into the development of new packaging.

Develop tool to enable assessment of packaging against the SPG.

Usable tool developed by December 2013.

Tool concept prepared by Sep 2013

Tool in existence and tested by Dec 2013

Development of an independent tool isn’t a necessary step but is often useful.

Integrate SPG into existing packaging design process for all new packaging.

Integration complete and SPG assessment in progress by September 2013.

Incorporation completed by September 2013

Assessment of new packaging beginning October 2013

If there is no packaging design process it may be more appropriate to integrate into the procurement process.

Integrate SPG into existing packaging review processes

Integration complete and SPG review assessments in progress by September 2013.

SPG incorporated into existing review processes by July 2013

Reviews of existing packaging begun by September 2013

Many organisations have a packaging review process for quality, performance and production requirements in place, and it may be appropriate to integrate the SPG into this process rather than developing a new system. Note: your review schedule should account for

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any existing system/s.

Review existing packaging within two year period against the SPG, and implement findings.

All existing packaging reviewed against SPG by June 2015.

20% complete Dec 2013

45% complete Jun 2014

70% complete Dec 2014

100% complete Jun 2015

Timeline is indicative only; shorter term milestones included for best practice.

Require all marketing department representatives to complete the Sustainable Packaging Covenant Toolkit

All representatives to have completed toolkit by December 2013.

HR Manager to include Toolkit on necessary training forms July 2013 and roll out

All marketing department members to complete Toolkit by December 2013

Marketing departments often make key product design decisions. The toolkit is available here: http://www.packagingcovenant.org.au/toolkit/

Integrate the Sustainable Packaging Covenant Toolkit as an induction requirement for all new staff involved in the design or procurement of packaging

Toolkit integrated into existing induction program by December 2013.

Toolkit included in induction program by Dec 2013

All new staff being inducted into Toolkit by Jan 2014

Where appropriate, integrate sustainable packaging requirements into existing systems to improve uptake

Document and report any actual or attempted changes to packaging identified as part of reviews or otherwise, where possible including quantifiable data.

Changes documented and reported annually.

Ongoing process, reported in annual report

In addition to implementing sound systems it is important to demonstrate any attempts to improve the environmental performance of packaging.

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Performance Goals and KPIs Actions Target Milestones Notes

2. Recycling – the efficient collection and recycling of packaging

KPI 3: Proportion of signatories with on-site recovery systems for recycling used packaging

KPI 3 requires signatories to have in place recovery systems for used packaging, but could also cover other on-site recovery, recycling and reuse actions. The APC understands that most organisations are likely to have in place a recovery system; if this is the case the focus is therefore on continuous improvement of the system in place. Simply stating there is a system in place is not considered sufficient. Signatories should:

1. Describe how they will identify existing waste streams and opportunities to improve these; 2. Develop and maintain systems to:

i. Recover or recycle used packaging on-site; ii. Recover or recycle other materials on-site;

iii. Reuse packaging and delivery materials; and/or iv. Report volumes of waste diverted from landfill.

Complete a baseline waste assessment to identify:

- Total waste quantities - Recyclable content

currently appearing in waste

- Total amount of packaging that is recycled

- Packaging reused on site.

Waste and recycling baseline measurement completed to allow assessment for improvement.

Baseline established by June 2014 Assessment systems in place by September 2013. Assessment completed by January 2014.

The success of waste reduction and recycling programs can’t be assessed without comparison to an initial baseline. This baseline may be qualitative or quantitative dependent on available resources.

Establish recycling and environmental impact committee to identify recycling and reuse opportunities.

Committee established to have regular meetings with minutes recorded for follow-up.

Biannual meetings with minutes recorded, and follow-up also recorded.

Establishing a committee to pursue environmental outcomes may help identify and respond to opportunities.

Review locally available recycling and reuse options, prioritise these in terms of viability, and contact relevant stakeholders.

Annually updated list of local recovery options, and review of on-site waste streams to identify what may be able to be reused or recycled. At least one option identified

Initial list prepared August 2013. Contact with suppliers initiated from December 2013. Annual review taking place in January each year.

Working with other local businesses and community groups may assist in making recovery of used materials more economically viable.

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and stakeholder contacted annually.

Identify potential to return used packaging to suppliers, and preferentially purchase products from these suppliers.

Suppliers with take-back programs identified and included as preferred suppliers.

Suppliers reviewed for process by September 2013. Where suppliers with take-back programs exist, initiate preferential purchasing from Dec 2013. Annually review supplier processes for additional take-back options.

Removing products from the waste stream is likely to improve operational costs. Reuse may be a viable option (particularly in the case of transport packaging).

Ongoing monitoring of recovery system included in operational procedures

Monitoring included with an aim to identify 5% improvement opportunities annually.

Monitoring systems in place by December 2013 Ongoing monitoring to be reported in annual report.

It is important to not only monitor waste streams, but include actions and targets that seek to improve recovery rates.

Install and manage on-site recycling facilities in all staff areas including kitchens and office areas.

Recycling facilities available in all staff areas. Staff training provided and embedded within new employee induction program.

Areas lacking recycling facilities identified by September 2013 New facilities installed in these areas by October 2013 Recycling training included in new staff induction by October 2013 Existing staff inducted in recycling training October 2013

Many businesses focus on operational waste. Opportunities may also exist in office and administration areas to capture used packaging and office consumables.

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Initiate take-back programs for pallets, layer sheets and cardboard shippers.

Take-back scheme initiated with an aim to achieve 90% return of these materials by June 2014.

Suppliers with take-back programs identified by August 2013 Take-back programs implemented September 2013 90% take-back of these materials by June 2014

Reuse may be a viable option (particularly in the case of transport packaging). The selected items for take-back are examples only.

Implement recycling of scrap metal / waste metal used in the factory / warehouse.

Scrap metal collector employed to recycle all used metal and obsolete equipment. Obtain report re: tonnage collected.

Identify local scrap metal collectors and ask for EOI (expressions of interest) Issue contract for scrap metal collection on regular basis. Collect tonnage reports and include in annual reporting

Incorporating packaging and non-packaging waste streams may improve recovery pay-backs.

Issue reusable pallets to suppliers for re-use instead of accepting disposable pallets / packaging.

Number of pallets required on site to allow collection on a weekly basis identified. Pallets purchased and system implemented to issue them to suppliers as needed for use, and return to suppliers following the delivery of goods.

Quantity of pallets required identified by September 2013, in consultation with suppliers. Policy for pallet reuse written, approved and circulated to relevant suppliers by September 2013 Reusable pallets in circulation by October 2013

Most suppliers issue reusable pallets, but where they do not, there is potential for larger companies to issue suppliers with their own.

Identify items of secondary and tertiary packaging which have potential for reuse as protective packaging and utilise as such.

Review of existing secondary and tertiary packaging completed.

Review complete December 2013

A number of companies have identified that there is potential to use shrink wrap and cardboard from incoming

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10% of identified materials arriving on site reused as protective packaging inside delivery boxes by June 2014, with future expansion as applicable.

Collection and transfer systems in place by March 2014 Quantity of materials reused reported annually, with the aim to increase reuse

materials as part of internal protective packaging for outgoing deliveries.

Recover recyclable packaging from obsolete products prior to disposal, and recycle

90% recyclable packaging separated and recovered from obsolete products at point of disposal for recycling.

Policy in place September 2013 Recovery of materials to occur as products become obsolete

Performance Goals and KPIs Actions Target Milestones Notes

2. Recycling – the efficient collection and recycling of packaging

KPI 4: Proportion of signatories with a policy to buy products made from recycled packaging or materials.

KPI 4 requires signatories to develop and implement a policy that drives the procurement of products containing recycled packaging. The intention of this KPI is to improve the market demand for recovered packaging, which is likely to improve the commercial viability of packaging recovery. As packaging is often recycled into non-packaging products, the APC encourages organisations to develop policies that cover a wide variety of products that may extend beyond packaging. The key components of the KPI are:

1. The establishment of a policy to preferentially buy products made from recycled materials 2. To document and demonstrate the implementation and adoption of the policy, leading to an increase in the proportionate

purchasing of products containing recycled content.

Develop and document a Buy Recycled policy, and embed into existing purchasing procedure.

Documented policy developed and embedded by December 2013.

Written and approved procedure prepared by September 2013 Procedure incorporated into existing procedures by December 2013

It is important that the intent to purchase/ procure recycled content products is integrated into existing systems/ processes.

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Incorporate a buy recycled clause into existing purchasing policy.

Purchasing policy contains a buy recycled clause.

Clause incorporated and policy implemented from September 2013

Levels / proportions of recycled material purchasing would need to be reported annually to allow ongoing reporting against this action.

Annual review of Buy Recycled policy to pursue continual improvement.

Annual review conducted of purchases against sustainable packaging requirements and recent product developments.

Results of review reported annually.

Monitoring progress with an aim of continuous improvement will help to ensure greater uptake.

Develop and issue contracts to suppliers which give preference to products and packaging containing recycled materials.

Buy Recycled policy and sustainable packaging requirements to be incorporated into 100% of new supply contracts. Recycled content preference incorporated into broader contracts.

All new supplier contracts to include Buy Recycled policy and sustainable packaging requirements by January 2014 Existing contracts re-negotiated to include Buy Recycled policy and sustainability packaging requirements as renewed

It is important that the intent to purchase/ procure recycled content products is integrated into existing systems/ processes.

Review existing list of purchases to identify items with recycled content currently being procured and opportunities to expand and/or increase.

Complete review, and prepare list of items containing recycled content and opportunities for expansion by Mar 2014.

Baseline review of existing recycled content in purchases completed December 2013 Opportunities for expansion identified and ready for implementation March 2014

Your organisation may already be purchasing a range of products and packaging that contains recycled content. Often this content is not recognised until questions are asked of suppliers.

Trial alternative pallet stacking patterns that will allow increased recycled material in cartons.

Trial completed and, if successful, alternative stacking patterns costed and adopted.

Alternative pallet stacking procedures trialled by December 2013. Successful stacking pattern

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adopted by March 2013. Increasing recycled content in cartons from June 2013.

Identify and make use of opportunities to purchase items with increased recycled content for office use.

Opportunities identified with an aim of 20% of office stationery to contain recycled materials by June 2014.

10% of new office stationery to contain recycled materials by December 2013 20% of office stationery containing recycled materials by June 2014 Ongoing increases recorded in annual reporting

There are a wide range of office products that can contain recycled content, including office stationery and furniture.

Conduct annual review of glass and cardboard suppliers to determine the level of recycled product used with the aim of identifying improvement opportunities

Annual survey completed and acted upon. Actions arising from this documented and reported annually.

Initial survey completed by December 2013 Annual reviews conducted in March each year Opportunities for expansion identified, reported, and acted upon, then documented in annual reporting

Recycled content in certain raw materials results in reduced operational costs for suppliers. It is good business practice to understand the recycled content of your major material inputs.

Document and report recycled content purchases, reviewing these purchases to identify opportunities to increase year on year.

Report the items purchased and the percentage of recycled content, and any future opportunities to increase recycled content percentages across all purchases.

Items purchased and improvements reported annually.

It is important to demonstrate the application of the policy and report this annually.

Replace 50% secondary and tertiary packaging with materials containing recycled content.

Recycled materials incorporated into secondary and tertiary packaging.

10% secondary and tertiary packaging to contain recycled content by December 2013

Ongoing increases may be possible dependent on the nature of the product.

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30% December 2014 50% December 2015

Audit existing buy recycled purchasing policy for areas for expansion or improvement

Opportunities for improvements against Buy Recycled goal identified and implemented as practical.

Bi-annual audit to be conducted and findings implemented as practical

A target like this allows ongoing reporting of the implementation of findings.

Formalise existing warehouse purchasing policies to give preference to products with recycled content.

Formal policies in place Policies in place by December 2014

Implement a Green Purchasing Guide taking into account the green accreditation(s) of suppliers and products and emphasising recycled purchasing.

Green Purchasing Guide developed and implemented.

Document developed June 2014 Policies implemented by September 2014

Performance Goals and KPIs Actions Target Milestones Notes

3. Product Stewardship – A demonstrated commitment to product stewardship by the supply chain and other signatories

KPI 6: Proportion of signatories that have formal processes for working with others to improve design and recycling of packaging

The key requirement for KPI 6 is to develop and demonstrate that formal processes are in place to work with suppliers regarding packaging sustainability; this could include arrangements with both material/product suppliers and service providers as well as not-for-profits and industry associations. However, actions under this KPI will vary substantially based on the industry and place in the supply chain of the signatory. To address this KPI, signatories should include items in their action plans which cover the following:

1. Developing, documenting, and using formal processes (such as contracts and supplier codes of conduct) for working with

suppliers and clients to improve packaging design and recovery; and 2. Implementing policy actions to improve packaging outcomes.

Instigate biannual meetings with suppliers to promote engagement with a goal of

Meeting held and outcomes documented.

Document outcomes biannually

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improving packaging design and recyclability.

Organise and schedule regular meetings with suppliers to identify continuous improvement projects, and provide assistance to implement.

Quarterly meetings with suppliers scheduled. Continuous improvement projects for implementation identified.

Initiate meetings with suppliers by September 2013 Continuous improvement programs identified by March 2014 Ongoing assistance provided with implementation of plans, with actions reported annually.

Better practice action plans should identify specific programs to be implemented. However, where consultation is needed with stakeholders, it may be appropriate to commit to identifying and working on projects with the supply chain.

Advertise participation in the APC, and encourage suppliers to become signatories.

Prepare and distribute to suppliers a statement outlining commitment to APC principles and encouraging participation.

Statement prepared and distributed in August 2013

Integrate packaging sustainability criteria into contracts as they are renewed and report annually.

Packaging sustainability criteria integrated into contracts on renewal and reported against annually.

Ongoing commitment with contracts updated as they are renewed. Annual reporting of inclusion of criteria.

The key component of the KPI is the implementation and application of formal processes.

Work with recycling contractors to improve material collection systems, including reducing contamination of materials.

Biannual meetings held to review and improve collection systems.

First meeting held by October 2013 Meetings minuted and outcomes included in annual reporting.

Formalise relationships with recycling contractors and purchasers of used materials.

Written agreements in place for all recycling contractors and materials purchasers.

Existing providers issued formalised contracts by December 2013

Instigate annual meetings with suppliers to identify new packaging options.

Minutes and follow up actions to meeting findings.

Outcomes and actions documented in annual reports.

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Liaise with global arm of business to incorporate international sustainability initiative into local practices.

Continuing dialogue with international offices to incorporate better sustainability practices for packaging and products into local business.

Initial dialogues occurring from August 2013 Dialogue ongoing, meetings minuted and emails retained, outcomes reported annually.

Where the Australian organisation is part of a global body, exploring and implementing sustainable initiatives from the global parent may be an excellent way to identify and resource initiatives.

Contact suppliers and survey their waste practice. Encourage suppliers to implement recovery / recycling procedures.

Contracts with suppliers preference suppliers who implement recovery / recycling procedures.

Survey complete December 2013 Ongoing support to suppliers to develop recovery / recycling systems, with outcomes reported annually.

Develop a procurement process where suppliers are required to submit suggestions for packaging improvement on regular basis.

Procurement process updated. Biannual meetings with suppliers organised.

Process in place December 2013 Biannual meetings and outcomes recorded and reported annually.

Develop a list of product stewardship partners and work with these during NPD to improve packaging and increase recycling

List developed June 2014 Active working partnerships established from July 2014

Outcomes reported annually.

Identify APC signatories amongst suppliers and preferentially purchase from these suppliers.

Complete survey of current suppliers to identify APC signatories. Prepare policy to preferentially purchase from APC signatories.

Survey complete March 2014 Policy prepared and ready for implementation March 2014

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Contact suppliers and review the Sustainable Packaging Guidelines for implementation, using their input to increase the effectiveness of its implementation.

Contact suppliers and distribute SPGs for review. Supply meetings to include review of the SPG principles and identify possible improvements.

Suppliers contacted and SPGs distributed December 2013 Supplier meetings to raise SPG principles. Outcomes reported annually.

This would be a good action to incorporate into existing communications with suppliers. Particularly where there is ongoing communication, there will be opportunities to identify and implement improvements as they become available.

Develop and issue contracts which give preference to suppliers whose performance incorporates sustainability criteria.

Requirement for sustainability statement to be incorporated into all new contracts in place.

All new supplier contracts to include sustainable packaging policy statement by January 2014

Performance Goals and KPIs Actions Target Milestones Notes

3. Product Stewardship – A demonstrated commitment to product stewardship by the supply chain and other signatories

KPI 7: Proportion of signatories demonstrating other product stewardship outcomes

KPI 7 provides signatories with a platform to promote ‘other’ sustainability-focussed programs and further develop systems to better manage environmental and social impacts. Ultimately, these impacts directly or indirectly influence the sustainability footprint of your organisation’s packaging and initiatives to manage these should be included under KPI 7. Whilst this KPI does ask signatories to extend the principles of product stewardship beyond packaging, better plans may make reference to how the initiatives will lead/have led to better packaging sustainability outcomes. To address KPI 7, signatories should include items in their action plans to:

i. Develop, document and maintain environmental programs for packaging and other purposes; ii. Report progress against these actions each year.

Include action plan outcomes in Corporate Social Responsibility reporting.

Inclusion of APC-relevant outcomes in annual CSR report.

APC annual report outcomes included in CSR reporting

Your action plan contents can help contribute to environmental sustainability, which should be included in your Corporate Social Responsibility report.

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Identify and address areas of improvement for event waste management.

Problem areas identified and addressed as they occur.

Ongoing commitment to be annually reported.

Include information on packaging to inform customers about the environmental footprint of their selected products.

Product range to indicate relative environmental performance of product packaging.

Environmental footprint of product ranges assessed – 30% complete by June 2014 70% complete June 2015 100% complete December 2015 Information included on product packaging from March 2015

Establish and implement product purchasing to ensure only the necessary product quantities are ordered/received, thereby reducing waste.

Expand use of just-in-time production to additional product and packaging suppliers.

Weekly monitoring of product packaging levels instigated from October 2013 Ordering processes based on stock levels initiated from November 2013, with ongoing review of effectiveness

Increase use of lightweight glass and PET bottles in place of standard glass for bottling.

Increase use of lightweight glass and PET by 10% per annum.

Opportunities for effective use of lightweight and PET bottles identified December 2013 Rollout of additional products in lower impact bottles from June 2014

The components identified for alteration or replacement here are examples only – different materials or processes will be appropriate for different signatories.

Promote recycling of caps and dividers by incorporating recycling information for dividers and initiating a take-back program for caps

Recycling info incorporated into artwork approvals process by Jun 2014. Take-back scheme trial to

Appropriate recycling information identified by December 2013 and provided to marketing department

This item was developed by a winery, but a similar action can be adapted for other industries.

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commence by December 2013. Recycling information incorporated from Jun 2014. Take-back scheme implemented from December 2013

Provide used cartons to the local community to prevent businesses / individuals buying new packaging.

Availability promoted and level of customer uptake reported annually.

Used carton availability advertised from September 2013 Level of uptake reported annually

Maintain ISO 14001 certification and environmental management system across all applicable sites.

System and certification maintained and reported annually.

Certification reported annually Environmental certification systems like ISO 14001 aim to continuously improve your organisation’s environmental performance, which can be part of product stewardship.

Continue to expand and promote carbon neutral product ranges.

Range expanded and reported annually.

Opportunities identified by March 2014 Ongoing implementation reported annually

Support industry and community waste and recycling events and initiatives wherever applicable to demonstrate our commitment to reducing waste.

Ongoing participation with annual increase in total participants.

Events identified and participation reported annually.

Establish composting systems / hire composting providers for management of product wastage.

50% organic wastage diverted from landfill to composting systems.

Composting system in place by December 2013 System maturation / expansion June 2014

This will only be a viable action where the product is food based or otherwise compostable.

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50% organic waste to compost December 2014

Implement packaging take-back programs at point of sale, including capacity for type segregation.

Provide take-back facilities at point of sale, and advertise to customers by June 2014.

Options for use of packaging returned through program identified by September 2013 Facilities for collection in place by December 2013 Promotion to customers and acceptance of packaging by June 2014

Extending recovery programs to others in your supply chain may result in packaging recovery being more cost viable due to increased volumes available for collection.

Performance Goals and KPIs Actions Target Milestones Notes

3. Product Stewardship – A demonstrated commitment to product stewardship by the supply chain and other signatories

KPI 8: Reduction in the number of packaging items in litter

Actions and targets under KPI 8 should relate to your organisation’s approach to improving litter management, that being packaging/products that, rather than being disposed of in a bin, are found in public places or the broader environment (streets, parks, drains, beaches, waterways, etc.). It is important that the plan focusses on actions/targets that reflect your organisation’s potential litter impacts. To address this KPI, signatories are asked to include actions which incorporate some combination of the following:

i. Provide improved disposal information on their product packaging; ii. Reduce the number of separable parts in their packaging which are likely to become litter;

iii. Reduce the presence of litter on and around their own site(s); iv. Participate in litter reduction activities in their local community.

It is not sufficient to simply state that your packaging is unlikely to become litter. If litter is not a material issue it is important that you demonstrate this is the case and that measures have been enacted to account for whatever litter issues there are.

Add requirement for the Tidyman logo and phrase “Please Recycle” or “Please dispose in bin” to be shown on all primary

70% of packaging to show messages by May 2014, 90% by May 2015.

Review of existing packaging undertaken annually and logos included 70% of packaging to show logo

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and secondary packaging as part of the annual label review.

by May 2014, 90% by May 2015

Investigate options to reduce number of removable, lightweight packaging items per product, targeting products more likely to be consumed away from home, and develop plan to implement identified methods.

Investigation undertaken. Plan developed to account for findings.

Review undertaken by December 2013 Opportunities identified and implementation begun June 2014 Outcomes reported in annual report

Support a local litter reduction program.

Annual financial support provided to the selected program.

Funds selected by September 2013 Donations to be reported in annual report.

Review the use of space fill material options in shipping cartons and identify options that minimise litter propensity.

Options and carton reviewed. Alternate options identified and sourced.

Review complete December 2013 New products in use by September 2014 or as existing carton stock used.

Review disposal options for screw-caps and promote best option.

Complete disposal option assessment and select most sustainable option(s) for promotion.

Review complete by December 2013 Option(s) for promotion identified and promoted by June 2014

This item was developed by a winery, but a similar action can be adapted for other industries.

Participate in Business Clean Up Day on an annual basis with an aim to increase participation year on year through internal promotion.

BCUD promoted annually. Number of staff participating and number of bags filled documented and reported.

Annual participation completed and reported

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Identify areas/activities on all sites that have the highest litter potential and initiate, improve or maintain litter management systems in those areas.

Litter management system in place on all sites and reported against annually.

Areas identified and ranked according to risk by December 2013 Systems reviewed and plan to manage implemented by March 2014 Activities to manage litter reported annually.

Manage litter in staff break areas on site.

Common lunch and smoking break locations identified. Weekly clean-ups of these areas scheduled.

Areas identified by December 2013. Weekly clean-ups scheduled from February 2014 Maintenance actions reported annually.

Maintain litter patrol as part of housekeeping procedure and include requirement to monitor litter onsite.

Weekly litter patrols maintained. Monthly monitoring program established and tracked.

Patrols conducted weekly or as required Monthly tracking data consolidated for annual reporting.