exploring extended producer responsibility: waste tyres as
TRANSCRIPT
Exploring Extended Producer Responsibility:
Waste Tyres as a Resource for Job Creation in South Africa?
by
Sydney Ellen Baker
A thesis submitted in conformity with the requirements
for the degree of Master of Arts
Department of Geography and Planning
University of Toronto
© Sydney Ellen Baker, 2018
ii
Exploring Extended Producer Responsibility:
Waste Tyres as a Resource for Job Creation in South Africa?
Sydney Ellen Baker
Master of Arts
Department of Geography and Planning
University of Toronto
2018
Abstract
Extended producer responsibility (EPR) has emerged globally as a means shift the
increasing costs of waste management of end-of-life products onto the producer. This research
focused on an EPR scheme for waste tyres that was legislated by the South African government
in 2012. While sharing many similarities with other EPR schemes, the South African program
was unique in its focus on creating employment. More specifically, in response to the injustices
of South Africa’s apartheid there was a focus on the upliftment of previously disadvantaged
individuals. Based on semi-structured interviews with actors from various roles in the waste tyre
system, this research investigated how the EPR affected employment and whether EPR can be
used to create jobs. The EPR scheme for waste tyres in South Africa was found to have increased
employment, however, potential challenges with using EPR as a tool for job creation were
identified.
iii
Acknowledgements
I would like to extend my gratitude to all my research participants who took the time to
speak with me and enabled my understanding of the waste tyre system in South Africa and how
it was affected by the EPR scheme. Without their willingness to meet with me and their insights
this research would not have been possible. I would also like to thank my co-supervisors, Dr.
Virginia Maclaren and Dr. Thembela Kepe, for their guidance throughout the research process.
My co-supervisors, alongside my additional thesis committee members Dr. Raj Reddy and Dr.
Alana Boland provided valuable feedback to finalize this thesis and I thank them for their
thoughtfulness. Finally, I would like to thank my family and friends, for listening with interest to
my developing understanding of waste management and tyre recycling, and for supporting me
through reading drafts of this thesis.
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Contents
Acknowledgements ...................................................................................................................................... iii
List of Acronyms ........................................................................................................................................ vii
Chapter 1 – Introduction ............................................................................................................................... 1
1.1 Overview of the EPR Scheme for Waste Tyres .................................................................................. 1
1.2 Objectives ........................................................................................................................................... 4
1.3 Significance......................................................................................................................................... 6
1.4 Outline of Thesis ................................................................................................................................. 7
Chapter 2 – Context ...................................................................................................................................... 9
2.1 Extended Producer Responsibility ...................................................................................................... 9
2.2 Circular Economy ............................................................................................................................. 15
2.3 End of Life Management for Tyres ................................................................................................... 17
2.4 Historical Context of South Africa ................................................................................................... 20
2.5 Informality in South Africa ............................................................................................................... 22
2.6 BEE in South Africa ......................................................................................................................... 25
2.7 Trends in Waste Management in South Africa ................................................................................. 30
2.8 Legislative Context ........................................................................................................................... 34
2.9 The REDISA Plan ............................................................................................................................. 39
2.9.1 Substance of the REDISA Plan .................................................................................................. 40
2.9.2 Waste Tyre System under the REDISA Plan ............................................................................. 42
2.9.3 Issues with the Implementation of the REDISA Plan ................................................................ 44
2.9.4 Current State of the REDISA Plan ............................................................................................. 46
2.10 Waste Tyre EPR Case Studies ........................................................................................................ 47
Chapter 3 – Methods ................................................................................................................................... 52
3.1 Study Areas ....................................................................................................................................... 52
3.2 Participant Recruitment .................................................................................................................... 52
3.3 Interview Participants ....................................................................................................................... 54
3.4 Data Collected ................................................................................................................................... 60
3.5 Data Analysis .................................................................................................................................... 64
3.6 Limitations ........................................................................................................................................ 65
Chapter 4 – Results ..................................................................................................................................... 67
4.1 Waste Tyre Management in South Africa ......................................................................................... 67
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4.2 Benefits and Criticisms of the REDISA Plan ................................................................................... 69
4.2.1 Good Plan/Bad Management ..................................................................................................... 69
4.2.2 Environmental ............................................................................................................................ 70
4.2.3 Operations .................................................................................................................................. 72
4.3 Role of Government .......................................................................................................................... 76
4.3.1 Waste Bureau’s Management of the REDISA Plan ................................................................... 79
4.4 Job Creation ...................................................................................................................................... 81
4.4.1 Waste Bureau ............................................................................................................................. 85
4.4.2 Recruitment of Actors Under the REDISA Plan ........................................................................ 86
4.4.3 Political Appointments Under the REDISA Plan ...................................................................... 89
4.5 Integration of Actors from the Existing Informal Sector .................................................................. 92
4.5.1. Transporters .............................................................................................................................. 92
4.5.2 Micro-collectors ......................................................................................................................... 96
4.5.3 Processors in the Informal Sector .............................................................................................. 98
4.6 Business Creation .............................................................................................................................. 99
4.6.1 Depots ........................................................................................................................................ 99
4.6.2 Transporters ............................................................................................................................. 101
4.6.3 Micro-collectors ....................................................................................................................... 102
4.7 Supports for Processors ................................................................................................................... 106
4.7.1 Supply ...................................................................................................................................... 107
4.7.2 Subsidy ..................................................................................................................................... 108
4.7.3 Processing in South Africa ....................................................................................................... 110
4.7.4 Legislative Requirements ......................................................................................................... 113
4.8 Sustainability................................................................................................................................... 115
4.8.1 Lack of Processing ................................................................................................................... 117
4.8.2 Longevity ................................................................................................................................. 119
4.9 Summary of Findings ...................................................................................................................... 122
4.9.1 Waste Tyres as a Hazard .......................................................................................................... 123
4.9.2 Waste Tyres are a Resource ..................................................................................................... 124
4.9.3 Waste Tyres as a Governable Object ....................................................................................... 126
Chapter 5 Conclusions .............................................................................................................................. 130
Works Cited .............................................................................................................................................. 137
Appendix A ............................................................................................................................................... 144
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Appendix B ............................................................................................................................................... 145
Appendix C ............................................................................................................................................... 147
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List of Acronyms
BBBEE – Broad-Based Black Economic Empowerment
BEE – Black Economic Empowerment
DEA – Department of Environmental Affairs (formerly the Department of Environmental
Affairs and Tourism)
ECA – Environmental Conservation Act
EIA – Environmental Impact Assessment
EPR – Extended Producer Responsibility
ERTMA – European Tyre and Rubber Manufacturer’s Association
IIWTMP – Integrated Industry Waste Tyre Management Plan
IWMP – Industry Waste Management Plan
NEMA – National Environmental Management Act
NEMWA – National Environmental Management: Waste Act
NWMS – National Waste Management Strategy
OECD – The Organisation for Economic Co-operation and Development
PRO – Producer Responsibility Organization
REDISA – The Recycling and Economic Development Initiative of South Africa
RMI – Retail Motor Industry
SMME – Small, Medium Micro-Enterprises
SARS – South Africa Revenue Service
SATRP – South African Tyre Recycling Program
SAWIS – South African Waste Information System
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Chapter 1 – Introduction
South Africa, as with other countries around the world, is faced with the challenge of
managing expanding varieties and volumes of waste products. Extended producer responsibility
(EPR) has emerged globally as a way to shift the increasing costs of waste management of end-
of-life products onto the producer of those products (OECD, 2016). In 2012 South Africa
legislated an EPR scheme to manage waste tyres (REDISA, 2012). While sharing many
similarities with other EPR schemes, the South African program was unique in its focus on
creating employment through developing an industry around waste tyres (REDISA, 2012).
Through generating employment, the EPR scheme sought to address some of the injustices of
South Africa’s apartheid by creating opportunities for small businesses and the upliftment of
previously disadvantaged individuals (REDISA, 2012). This research will investigate how the
EPR scheme for waste tyres affected employment in South Africa and whether EPR can be used
as a tool for job creation.
1.1 Overview of the EPR Scheme for Waste Tyres
Prior to the EPR legislation, there was no management in place for waste tyres in South
Africa. Most tyres were either landfilled or dumped in the environment (Nkosi et al., 2013;
Phale, 2005). Tyres pose a considerable risk for fire and for the spread of disease as stockpiles
become a breeding ground for mosquitos and vermin (Phale, 2005; Park et al., 2018). In South
Africa, many tyres were also burnt to recover steel within them which also has health risks and
causes environmental degradation (Phale, 2005; Muzenda & Popa, 2015; DEA, 2012). There was
some existing industry around the processing of waste tyres, but it is estimated this accounted for
just 4% of waste tyres arising in South Africa (REDISA, 2015a). In 2009 the Waste Tyre
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Regulation banned the landfilling of tyres and create the legal framework for an integrated
industry waste tyre management plan (IIWTMP) (RSA, 2009).
The EPR plan for waste tyres was submitted in response to the governments call for
IIWTMPs to address the management of waste tyres in South Africa (Nkosi et al., 2013). The
Department of Environmental Affairs (DEA) approved the plan submitted by the Recycling and
Economic Development Initiative of South Africa (REDISA) in November 2012. As stated in a
press release from the DEA in December 2012 the Department’s hope was “that all stakeholders
can now focus on the implementation of the approved REDISA Integrated Industry Waste Tyre
Management Plan to ensure that we achieve the objects of the Constitution on the protecting of
the environment and our people’s well being, while also ensuring that we provide meaningful job
opportunities to our communities” (DEA, 2012: 2). The plan laid out the requirements for
various actors within the tyre system and their obligation towards the management of waste
tyres. The plan set out that a fee would be levied on each tyre produced in or imported to South
Africa and paid to REDISA. That fee would then be used to fund the collection, storage,
transportation and processing of waste tyres, as well as related education and research about
waste tyres.
As is common with EPR schemes, one of the goals of the REDISA plan was to reduce the
impacts of waste tyres on the environment and minimize the risks associated with waste tyres
(OECD, 2016; REDISA, 2012). Similarly, EPR schemes are recognized to drive economic
growth through the industry they create around the collection and treatment of waste, however
the REDISA plan was unique in its emphatic focus on job creation (OECD, 2016; REDISA,
2012). In 2017, unemployment in South Africa was at 26% (World Bank, 2017) and therefore
job creation was an important consideration for this project, especially as it was undertaken by
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government. However, beyond simply creating jobs, the REDISA plan was used as a method to
address the historical oppression of black and coloured South Africans and it integrated the
country’s policies of Black Economic Empowerment (BEE). The REDISA plan tried to address
this through creating opportunities specifically for those who were denied access to opportunities
in the past. In seeking to uplift previously disadvantaged individuals (PDIs) the REDISA plan
also considered the integration of actors in the informal sector, such as existing waste tyre
transporters, within the formalized waste tyre system.
To achieve its parallel environmental and job creation goals, REDISA set out to establish
a formalized system for tyre collection and storage throughout the country. This would be done
through the efforts of micro-collectors, waste tyre transporters and waste tyre depots which were
appointed under the REDISA plan (REDISA, 2012). REDISA was also responsible for
supporting the establishment of waste tyre processing operations such as rubber crumbing and
pyrolysis (REDISA, 2012).
REDISA began operations in 2013 but was shut down pre-emptively in 2017 when the
government changed the way fees were collected and distributed. Passed in 2016, new legislation
required that fees be paid to the South Africa Revenue Service (SARS) and then released to
managers of integrated waste management plans, such as REDISA, upon submission of a
business plan (RSA, 2016). REDISA did not submit an approved business plan and ceased
operations in June 2017 due to lack of funds (PCEA, 2017).
A newly established branch of the DEA, the Waste Bureau has since taken over operation
of the REDISA plan (PCEA, 2017). The Waste Bureau took on the contracts that existed
between various actors in the system and REDISA and the operation of the plan has not changed
significantly (PCEA, 2017). As per the new legislation, the waste tyre levy is being collected by
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SARS and then transferred to the National Treasury before being released to the Waste Bureau
(PCEA, 2017).
1.2 Objectives
Due to the unique emphasis of the REDISA EPR scheme on job creation for PDIs it is an
interesting case study to consider how EPR can be used as a tool to generate employment.
Through this research I have sought to understand how the REDISA Integrated Industry Tyre
Waste Management Plan affected employment in South Africa. Specifically, this research
focused on the following key questions:
1. How and for whom were jobs created under the REDISA plan?
2. Were actors in the informal sector integrated into the plan?
3. How were actors within the waste tyre system supported by REDISA?
4. Was the waste tyre system established by REDISA, and the jobs within it,
sustainable?
To respond to these questions, I considered numerous aspects of the waste tyre system as
it operated prior to and under the REDISA plan, as well as under management of the Waste
Bureau. I have studied the role of all actors within the waste tyre system as the system is
interconnected and relies on the functioning of the entire system. I have looked at who was
included or excluded under the plan. Additionally, I have considered the costs and benefits to
actors involved in the implementation of the REDISA plan. In order to draw conclusions around
these key questions, I have used a lens of political ecology, as it is a useful tool to highlight how
the waste tyre system which was developed under the REDISA plan was influenced by South
African politics and history.
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While the use of waste tyres is a means for individuals to earn a livelihood, some of the
uses for end-of-life tyres, such as burning for steel recovery, have negative environmental
impacts (Phale, 2005; DEA, 2012). Further, through their call for IIWTMPs the government
created the impetus for waste tyres to be governed. Where waste tyres can be seen as an
environmental hazard, a resource and a governable object, political ecology is a useful tool to
understand how waste tyres have come to be managed in South Africa. In this research I have
invoked political ecology to seek to understand how political and economic factors have affected
who is employed in the waste tyre system as well as the benefits that actors at different levels
were able to derive from their involvement with the plan.
In understanding relationships between waste management interventions and
sociopolitical factors, political ecology has been shown to be an effective lens (Njeru, 2006;
Pickren, 2014; Reddy, 2016). Njeru (2006) used political ecology to describes the complexities
of reducing plastic bag waste in Kenya by demonstrating that bag waste is felt most strongly in
low income communities where the lack of sanitation services has led residents to use plastic
bags as “flying toilets”. This coupled with a lack of political will to impose restriction on the
plastic bag industry has caused inertia in addressing the problem of plastic bag waste (Njeru,
2006). This illustrates the complex interaction between politics, social issues and the
environment that affect how objects are understood and governed. As Pickren (2014) describes
with regards to electronic waste, "a political ecology approach understands e-waste and e-waste
landscapes as being produced through particular processes that are historical and geographical,
social and natural, and always shaped by asymmetrical relationships of power" (119).
Political ecology underscores the political relationship between humans and environment,
and understands that the relationships between human and non-human (waste tyres) actors are
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political (Robbins, 2012). Through a dialectical understanding, political ecology shows that
waste tyres do not simply exist, but that they have been constructed as hazard, resource and now,
through the EPR legislation, a governable object. Further, political ecology understands that the
costs and benefits associated with these constructions of waste tyres are distributed unequally,
that they act in relation to existing social and economic inequalities and that this has political
implications for the power of actors within the system (Bryant and Bailey 1997, 28-29 as cited in
Robbins 2012, 20). In order to understand how different actors in the waste tyre system have
been affected, it is important to look to the political and consider the “influence of variables
acting at a number of scales, each nested within another” (Robbins 2012, 20). Different actors at
different scales have different motivations for the way that waste tyres are constructed, and I
have explored the costs and benefits of these constructions for various actors.
When considering the case of waste tyres in South Africa, political ecology invites us to
consider how the solution to an environmental problem became a tool for job creation. While the
efforts to collect and process waste tyres were motivated by the risks that they present to the
environment and health, the REDISA plan was strongly influenced by South Africa’s apartheid
history and driven by a political goal to use the waste tyres as a resource to remediate the
resulting poverty by creating jobs.
1.3 Significance
This research should contribute to an understanding of EPR schemes especially in terms
of their effect on employment which has not been widely studied to date. Through a lens of
political ecology, I should contribute to an understanding of the social affects of EPR systems as
I seek to understand how employment was affected. Particularly this research contributes to an
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understanding of how waste policies such as EPR can be used to address the lack of
opportunities available to historically oppressed populations.
The South African government has recognized the value of waste in creating employment
and this is part of the motivation behind the current EPR legislation (Godfrey & Oelefse, 2017).
As the government is currently in the process of establishing similar EPR schemes for other
waste streams, I hope this research can contribute to their understanding of both the successes
and challenges of implementing EPR in South Africa. As this research explores the power
structures that exist within the EPR system, it also contributes to an understanding how to ensure
future EPR schemes effectively distribute the wealth that is contained with waste.
1.4 Outline of Thesis
In Chapter 2 of this thesis I have established the context of the EPR schemes for waste
tyres in South Africa from relevant literature on the subject. First, I have examined EPR and the
different tools that it encompasses as well as a brief discussion of the circular economy which is
succeeding it. I have also reviewed the available end-of-life processes for tyres. Next, I have
explored the historical context in South Africa and how this has contributed to current
informality, BEE policies, and waste management trends in South Africa. I then described the
legislative context leading up to the IIWTMP, and review the REDISA plan itself. Finally, I have
analyzed and compared other existing EPR schemes for waste tyres to the REDISA plan.
In Chapter 3 I have described my research methods. I have also described the research
participants and provided information about their roles in the waste tyre system.
In Chapter 4 I have presented the results of my interviews through exploring themes that
emerged throughout the research process. I have then considered my results through a lens of
political ecology.
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Finally, in Chapter 5 I have drawn conclusions from my research and made some
recommendations for the improvement of the IIWTMP which can also be considered for EPR
schemes globally.
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Chapter 2 – Context
2.1 Extended Producer Responsibility
Extended Producer Responsibility (EPR) emerged in the 1980s as a means for
governments to shift the costs of managing waste from the taxpayer to the producers of the
product (OECD, 2016). The Organisation for Economic Co-operation and Development (OECD)
defined EPR as “an environmental policy approach in which a producer's responsibility for a
product is extended to the post-consumer stage of a product's life cycle” (OECD, 2016:23). EPR
schemes are a tool that can be used to actualize the Polluter-Pays Principle. This principle is
derived from Principle 16 of Rio Declaration on the Environment and Development, which
reads:
“National authorities should endeavour to promote the internalization of environmental
costs and the use of economic instruments, taking into account the approach that the
polluter should, in principle, bear the cost of pollution, with due regard to the public
interest and without distorting international trade and investment.”
United Nations Conference on the Human Environment, 1992: 4
In the 1980’s when EPR schemes were emerging, post-consumer waste streams were
increasing both in volumes of waste and in the variety of materials encountered (OECD, 2016).
Municipalities, who are most often responsible for waste management, were struggling to
address the growing volumes and varieties of waste (OECD, 2016). In response to this many
governments adopted EPR schemes to reduce the burden of waste on municipalities. The OECD
has championed EPR schemes and has produced guidelines for their development and
implementation. There are currently more than 400 EPR systems worldwide for products such as
electronic equipment, packaging, tyres, vehicles and lead-acid batteries (OECD, 2016).
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EPR schemes were developed with the expectation of achieving numerous goals. Firstly,
EPR emerged to fund waste management and reduce the reliance on public funds. Another aim
of EPR schemes was to increase recycling by diverting more waste away from landfills. A
further goal of EPR was to motivate producers, by making them accountable for the costs, to
improve their products to facilitate their end-of-life management. Producers could be encouraged
to redesign their products to make disassembling and therefore recycling easier. Alternatively,
producers could redesign to substitute product materials to minimize volumes or increase content
of recycled materials or to remove components that may be harmful to the environment and are
therefore more expensive to dispose of.
In a review of EPR schemes currently operating, the OECD attempted to determine if
EPR schemes are contributing towards reaching these goals. They have found limited evidence
to support these claims, however they have noted the following.
1. There is evidence that EPRs have contributed to reducing waste disposal and
increasing recycling;
2. The impact of EPRs on eco-design has been less than originally hoped for;
3. Some evidence that EPR systems have helped reduce financial burdens on public
budget and taxpayers;
4. Some evidence that EPRs generate economic opportunities as well as environmental
benefits;
(OECD, 2016: 30-34)
To date studies with regards to EPR have focused primarily on the ability of EPR to
influence product design, the success in removing waste from the environmental and the
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economic and/or environmental benefits associated with the proper disposal and reuse of
materials (Kojima, Yoshida, & Sasaki, 2009; Milanez & Bührs, 2009; Manomaivibool, 2009;
Akenji, Hotta, Bengtsson, & Hayashi, 2011). Little attention has been paid to date to the socio-
economic benefits that come from EPR, and particularly with respect to job creation. As noted
above the OECD research does support that EPR generates economic opportunities and
recognizes that the global economic share of the recycling sector is increasing (OECD, 2016). It
is also widely understood and stated that increasing recycling leads to job creation, although
there appears to be a lack of research to support this assertion. In terms of EPR schemes driving
job creation, the OECD similarly claims that waste sectors create and sustains thousands of jobs,
but admits that the data available is insufficient (OECD, 2016).
The OECD identified four categories of EPR instruments, these are product take-back
requirements, economic and market-based instruments, regulations and performance standards,
information-based instruments (OECD, 2016). These EPR instruments are summarized in Table
1. EPR schemes may use one or more of these techniques, and often combine several instruments
to achieve better management of post-consumer products. Indeed, “EPR programmes can (and
are likely to) contain a package of policy instruments such as fees, subsidies, bans/restrictions,
permits, targets, standards, labels, information campaign” (Manomaivibool, 2009: 137). Through
these EPR instruments, producers can be made responsible for either or both the financial and
physical burdens of their waste products1.
1 A financial responsibility means that the producer must fund the collection and treatment of waste products but do not have to carry out these tasks themselves. Physical responsibility means they are must collect and treat the waste.
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Instrument Description
Product take-back
requirements
Sets either mandatory or voluntary targets for product or material
collection and in some cases recycling. These targets can be for
retailers or producers and may also provide incentives to consumers
to return a product
Economic and market-
based instruments
Provides financial incentives for EPR. There instruments include:
- deposit-refund, where a payment is made when a product is
purchased and repaid in full or part when the product is
returned;
- advanced disposal fees, where a fee is collected when the
product is purchased and used to fund post-consumer
collection and in some cases treatment of the product;
- material taxes, where virgin materials are taxed to encourage
the use of recycled or less polluting materials;
- upstream combination tax/subsidy, where the tax paid by
producers is used to fund waste treatment.
Regulations and
performance standards,
Sets mandatory or industry-imposed standards, such as minimum
recycled content, to encourage take-back of post-consumer products
Information-based
instruments
Raise public awareness through the following:
- reporting requirements;
- product and component labelling;
- information for consumers about producer responsibility and
waste separation;
- information for recyclers about materials used in products.
TABLE 1 – Extended Producer Responsibility Instruments – adapted from the OECD
(2016).
Of these policy instruments, the most commonly used are product take-back
requirements, which is used by 70% of EPR schemes globally. These are sometimes used in
conjunction with advanced disposal fees. Advanced disposal fees on their own make up another
16% of EPR schemes globally. Finally, deposit-refund instruments are used by the remaining
11% of programs. The OECD reports that the other policy instruments “appear to be used
infrequently, if at all” (OECD, 2016: 24).
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EPR schemes can be applied collectively to an entire stream of products, such as all tyres
produced or imported to a country, or individually to each producer or importer. It has been
argued that for an EPR scheme to achieve product redesign it needs to be applied individually
(Nnorom & Osibanjo, 2008). Benefits derived from redesign in a collective system are shared
with all other producers and creates a disincentive as its benefits competitors (Nnorom &
Osibanjo, 2008). However, most EPR schemes are applied collectively to achieve economies of
scale in logistics and share the risks associated with EPR schemes including orphaned products2
(OECD, 2016). In some markets where EPR has been applied individually, producers have still
collaborated in product collection and recycling (Nnorom & Osibanjo, 2008)
In many EPR schemes Product Responsibility Organizations (PRO) have been
established to facilitate the programs. PROs are third party organizations that are tasked with
managing an EPR scheme and often the take-back of the products being managed. It has been
found that EPR schemes are more successful where producers outsource the physical
responsibility for end-of-life products to a PRO (Gupt and Sahay, 2015). Most frequently PRO’s
are non-profit organizations, but they can also be for-profit or government agencies (OECD,
2016). PROs are generally funded by the producers and this can be done through either
voluntary or mandatory schemes. There has been some concern over schemes with only one
PRO operating monopolistically (OECD, 2016). More recently EPR schemes have been
emerging that use two or more PRO organizations in order to encourage competition and ensure
that funds are managed optimally (OECD, 2016).
2 Orphaned products are those which outlive their producer. In a collective system the costs for their end-of-life management are shared across all participants, however, responsibility for them in an individual system is difficult to ascertain.
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Where economic instruments are used, Gupt & Sahay (2015) found that EPR schemes are
more effective when the producer is responsible for payment into the scheme, rather than
retailers or consumers. In developing countries, where administrative capacity is more limited,
there have been problems collecting fees as producers and importers can be difficult to identify,
especially in second-hand or illegal markets (Akenji et al., 2011). This difficulty would increase
if the fee were collected from retailers or consumers as the points of collection would increase
and therefore the administrative capacity for oversight as well. It should be recognized that any
fee paid by producers is usually passed on to consumers of the product through increased product
prices.
In a study of Waste-Electrical and Electronic Equipment (WEEE) EPR schemes in
Europe, Asia and the USA, Fishbein (2002), defined as effective EPR program as one that:
• Focuses specifically on the waste generated by end-of-life products.
• Clearly defines what financial responsibility producers have for the collection,
transport, and recycling of their products at EoL [end-of-life].
• Sets meaningful targets for collection and recycling.
• Differentiates recycling from technologies such as waste-to energy conversion.
• Includes reporting requirements and enforcement mechanism.
• Provides producers with incentives to design for reuse/recycling.
• Provides consumers with incentives to return their used products.
(Fishbein, 2002)
In addition, Fishbein (2002) found that government procurement strategies that support the EPR
initiatives were beneficial. An example of this in the waste tyre system would be the government
support of projects that use asphalt containing rubber crumb. The above criteria are focused on
15
WEEE and driving product redesign, however, in principle they can be applied to any EPR
scheme and I will consider whether the REDISA plan meets these criteria in my conclusions.
Further aspects of EPR schemes will be discussed is section 2.7 with regards to waste
management in South Africa and in section 2.10 where global trends around waste tyre
management and case studies of EPR schemes for waste tyres will be discussed.
2.2 Circular Economy
The circular economy is a relatively new concept that has been emerging around waste
generation and management, that has influenced the discussion around waste in South Africa.
(REDISA, 2015a; Godfrey & Oelofse, 2017). The Ellen McArthur foundation, which is a known
proponent of the circular economy defines it as:
“an industrial system that is restorative or regenerative by intention and design. It
replaces the end-of-life concept with restoration, shifts towards the use of renewable
energy, eliminates the use of toxic chemicals, which impair reuse and return to the
biosphere, and aims for the elimination of waste through the superior design of materials,
products, systems and business models” (as cited in Hobson, 2016: 88)
The circular economy is driven by the idea of a scarcity of resources and calls for the design of
products in a way that there is no end-of-life but instead a cycle of continued use. It calls for the
resources contained in a product or the product themselves to be kept in use, or at a minimum for
the resources to be returned safely to the environment. The circular economy focuses on shifting
the economy away from our current consumer model, where we take, use and dispose, and into a
model where we are users, who collectively use a product, then repair, restore, reconstruct and
16
reuse. Because the circular economy does not place constraints on consumption it also promises
continued economic growth and job creation while meeting environmental goals. (Lazarevic &
Valve, 2017).
In order to achieve product reuse, the circular economy calls for a redesign of products to
increase their lifespan, enable their repair or repurposing and ease the recapture of resources.
Notably, product redesign was also primary goal of EPR. EPR schemes have largely failed to
encourage product redesign; the circular economy reemphasizes this need. It is recognized that
“the content of the expectations for the European circular economy are not in themselves overly
innovative” but instead “the expectations go little further than rehashing ideas and strategies of
the past” (Lazarevic & Valve, 2017: 66).
Considering tyres specifically, the European Tyre and Rubber Manufacturer’s
Association (ERTMA) explored the topic of the circular economy in their 2015 Report with
regards to end-of-life tyres. They praised the existing efforts, including EPR schemes which
prevent tyres from going to landfill and resulted in tyre collection. They claim, with some hubris
that, “with collection rates in much of Europe at 100% of arisings, the tyre industry is halfway to
a circular economy, for collection is half the battle” (ETRMA, 2015: 17). This and ETRMA’s
explanations of waste tyre “reuse” in waste-to-energy technologies points to a lack of
understanding of the extent of change called for by the circular economy. Furthermore, with
regards to product redesign to close the loop, ETRMA acknowledges that “materials recovered
from tyres going back into tyres, is not yet within reach due to high safety and environmental
performance and technological constraints” (ETRMA, 2015:17).
The circular economy concept has emerged as a popular goal for modern economies. At
the 2014 World Economic Forum it was “front and center” (Hobson, 2016: 89), and the
17
European Commission released a Circular Economy Package in December 2015 (ETRMA,
2015: 16). The Department of Environmental Affairs in South Africa has adopted the idea of the
circular economy as can be seen in its recent presentation with regards to new waste tyre
management plans, however, this was long after the development of the REDISA plan (DEA,
2018). Godfrey and Oelofse (2017) state that “South Africa, as with the rest of the world, is
standing on the brink of a new fifth, and global, stage, “The Future is a Circular Economy” (pg.
8). They speculate whether South Africa may be able to skip the prominent practice of waste-to-
energy technologies that dominate in Europe directly to a circular economy (Godfrey & Oelofse,
2017).
Although the circular economy concept was not in the original REDISA plan, it was later
adopted by REDISA and appears in their documents and was also used by management in media
interviews (REDISA, 2015a; Waste Management World, 2016). Despite discussion of the
circular economy, the REDISA plan and its operation remain within the EPR framework.
2.3 End of Life Management for Tyres
Globally it is relatively common for waste tyres to be managed through EPR schemes. In
a 2013 study of 384 different EPR schemes the OECD found that 17% of those policies were for
tyre management (as cited in OECD, 2016). In Europe there are 21 countries currently using
EPR schemes for the management of waste tyres with the first plan being introduced in 1994
(ETRMA, 2015). Recovery rates across Europe, including countries not using EPR schemes, are
96% for end of life tyres with 19 countries recovering 100% of end-of-life tyres (ETRMA,
2015). This is an increase from 1999 when just 55% of tyres were recovered across Europe and
only 2 countries recovered 100% of end-of-life tyres (ETRMA, 2015). This demonstrates that the
full collection of waste tyres is achievable.
18
In terms of re-use, waste tyres can be remanufactured through retreading, where a new
tread is applied to the casing, or remoulding, where new rubber is applied to the entire tyre
casing and then the tyre is shaped in a mold. Tyre retreading is in decline worldwide although all
car, truck and industrial tyres can be retreaded. There is some retreading which happens in
Europe, however this appears to be limited. In Spain, retreading is almost exclusively used in
truck and airplane tyres (Uruburu et al., 2013). In Germany, retreading has stagnated since 1995
and according to the body representing independent retreaders this is due to pressures on the
market for retread tyres from low priced tyre imports (ETRMA, 2015). Similarly, in Spain, it has
been determined that “passenger car tyre retreading will continue to be very limited, since new
tyre budget brands are very competitive in price, leaving no benefit in retreading” (Uruburu at
al., 2013). The low price of new tyres is thus reducing the competitiveness of retreads and this
makes it difficult to encourage it as an option for tyre reuse. Another use from waste tyres that
maintains them largely in their original form is use in engineering works including fortifying
embankments for erosion control and lining for landfills.
Recycling waste tyres to produce rubber crumb is similarly constrained because the
market for recycled rubber products continues to be limited. (Li et al., 2010). Applications
include rubber for artificial sport pitches and tracks, subflooring and soundproofing, playground
surfacing and incorporation into asphalt (Li et al., 2010, Ortíz-Rodríguez et al., 2017). Rubber
crumb can be produced through a mechanical process, where tyres are gradually ground down
and wire is separated out, or through a cryogenic process where tyres are cooled with liquid
nitrogen to the point of cracking (Phale, 2005; Corti, 2004). As stated in the ETRMA (2015)
report, “the reality is that markets for recycled rubber materials have been slow to develop and
without the arrival of alternative large-scale processes that consume or reuse tyre derived
19
materials, TDF [tyre derived fuel] risks becoming the largest single route to deal with ELT [end
of life tyres]” (pg. 14).
Pyrolysis is another tyre recycling technique which uses a chemical process at high
temperatures to reduce tyres to their constituent parts and then those components are either sold
or disposed of separately (Li et al., 2010). Pyrolysis is still a technologically difficult process and
the value of products varies based on the quality achieved through each respective process (Li et
al., 2010; Muzenda & Popa, 2015). Products recovered include gas, oil, carbon black, which can
be used as fuels (Li et al, 2010). The oil recovered cannot be directly used but can be further
processed into diesel (Li et al., 2010). Recovered steel can also be sold to recyclers (Muzenda &
Popa, 2015).
In Europe energy recovery continues to account for about 50% of processing of end-of-
life tyres (ETRMA, 2015). This number has fluctuated over the years, starting at 68% in1994,
and reaching a low of 46% in 2007 (ETRMA, 2015). One of the most prevalent energy uses for
waste tyres is fuel replacement in cement kilns. Processing in cement kilns accounts for 60% of
waste tyres generated in Austria, 38% in Germany, 8% in France and 6% in Britain (Uruburu et
al., 2013). Especially in light of a push towards a circular economy, energy recovery is
considered to be a less optimal treatment for waste tyres, as the resources contained are lost from
future use.
These trends in the use of waste tyres are important to consider in the development of
EPR scheme. As can be seen by the collection rates of almost 100% across Europe, many
countries are successful at collecting waste tyres (ETRMA, 2015). However, viable treatment
options of waste tyres remain limited, and most tyre are still used for waste-to-energy (ETRMA,
2015). In terms of meeting the product redesign goals called for by either EPR or the circular
20
economy, the opportunities for tyres are limited. One development is that silica can be added to
tyres instead of carbon black, which extends their lifespan (Park et al., 2018) However, since this
drives up the price of tyres, it would likely not be popular in a developing country (Park et al.,
2018). As discussed above, the reuse of materials from waste tyres to new tyres is still not
feasible; however, a new process of cryogenic size reduction is being developed which has the
potential to enable rubber to be reused into the production of new tyres (ETRMA, 2015).
The environmental impacts associated with different end-of-life treatments for waste
tyres have been considered through life cycle assessments and have shown that rubber crumbing
has the highest environmental costs (Corti, 2004l Li et al.,2010). In a life cycle assessment of
end-of-life tyres, Corti (2004) compared conventional waste-to-energy and processing in cement
kilns to cryogenic and mechanical rubber crumbing processes and found that the waste-to-energy
processes were better for the environment due to the avoidance of conventional fuels. In contrast,
the high energy required for either cryogenic or mechanical crumbing made them worse for the
environment (Corti, 2004). Li et al. (2010) did a life cycle assessment which compared pyrolysis
and rubber crumbing in China, and found that pyrolysis had lower environmental impacts, again
largely due to the high energy required for crumbing.
2.4 Historical Context of South Africa
South Africa has developed through a unique social history of colonization and apartheid.
The apartheid was a systemic and bureaucratic process that forced segregation of South Africans
by race. Black South Africans were removed from the cities and forced into separate areas. This
allowed the apartheid government to control their movement, education and work and created an
oppressed class of labourers which could be exploited. As will be discussed in this and
21
subsequent section, although the apartheid ended in 1994, it has left lasting effects on South
African society today.
Under apartheid the education system established for Black South Africans was to teach
basic literacy and numeracy so as to prepare Black South Africans to fulfill roles in the growing
industrial economy (Nkomo, 1981). This coupled with restrictions on the types of jobs and pay
that they could receive resulted in extreme poverty and high unemployment amongst Black
South Africans. As another means of oppression Black and Coloured South Africans were forced
to carry passbooks which specified where they could travel and live (Stull, Bell and Ncwadi,
2016). Black South Africans who did settle in urban centers often did so illegally and this caused
them to be subject to exploitation. As described by Miraftab (2004), this created “a large pool of
black informal laborers, mostly women, available for use and abuse by the dominant white
population and the economy” (Miraftab, 2004: 875). Due to these injustices under apartheid,
many Black South Africans continue to face poverty and precarity in employment which has
resulted in them seeking a livelihood in the informal sector as will be discussed further in section
2.5.
The segregation of South Africans in terms of where they could live, the education they
received and the jobs they could have created a highly unequal society. As stated by Miraftab
(2004), “under the apartheid regime, the principal tool of the state in its mode of capital
accumulation was the construction and stratification of distinct racial categories incorporated
hierarchically into the labor market” (pg. 875). Through these discriminatory state programs
wealth became concentrated in the hands of White South Africans. Alongside this accumulation,
Black South Africans “were denied education, wealth and upward mobility under apartheid”
(Southall, 2007: 70). These practices created a society that was highly stratified based on race.
22
It is important to understand that many continue to feel the effects of this oppression
today and poverty in South Africa continues to be experienced far more by Black and Coloured
South Africans. To counter this inequality, policies of Black-Economic Empowerment have been
implemented. These policies seek to promote employment and business opportunities for Black
and Coloured South Africans. Through promoting economic opportunities for previously
disadvantaged groups in South Africa, BEE seeks to equalize the wealth of South Africans
across the races. Black-Economic Empowerment is discussed in greater detail in section 2.6 of
this Chapter.
2.5 Informality in South Africa
Informality generally refers to people or activities that exist outside of legal structures
(Rogerson, 2000; Roy, 2005). A common conception of the informal-formal divide is that formal
is generally “rule-based, structured, explicit, predictable and regular” while informality
“spontaneous, tacit and effective” (McFarlane & Waibel, 2012: 3). This understanding of
informality is often applied to labour, although, informal work can be highly organized and
disciplined (McFarlane & Waibel, 2012). In many cases, work in the informal sector has been
understood as separate from formality, however, this notion has been challenged and instead it is
understood that the two are often linked and exist in tandem with each other (McFarlane &
Waibel, 2012; Roy 2005). An understanding that the two exist in collaboration challenges the
idea that a binary between informality and formality exists. Since informality is understood as
being outside of the law, it is a definition that is generally imposed on people from government
or other actors (McFarlane & Waibel, 2012; Roy, 2005).
Despite the broader discussions of informality that exist, in this research I will consider
actors operating outside of South Africa’s legislation to be informal. This includes tyre
23
transporters who are not registered as waste tyre transporters under the REDISA plan or for tax
purposes; all waste collectors, who are assumed not to be registered for tax purposes; and tyre
processors operating without the required permits and licenses.
In South Africa informality has developed in response to high unemployment. The 2017
official unemployment rate was at 26%, and this rate has remained above 22% since the late 90s
(World Bank, 2017). In considering the development of informality, Rogerson (2000) stated that
“the key explanatory factor for the establishment of informal economic enterprise is the slow
expansion rate of the formal economy and its absorption of new work seekers” (p. 681).
Furthermore, Rogerson (2000) finds that people are being pushed into the informal sector due to
an oversupply of labourers, rather than a demand for services that are provisioned by the
informal sector.
Work in the informal sector has been categorized into levels, with those at the
“survivalist” or lower-tier of informality having no choice about working in the informal sector,
but instead turning to the work due to a lack of alternatives to meet their subsistence needs
(Rogerson, 2000; Viljoen et al., 2016). At a “growth enterprise” or higher-tier are those who
leave formal work and enter the informal market because they anticipate earning more and there
is a chance of evolving into more formal business (Rogerson, 2000; Viljoen et al., 2016).
Growing informality in post-apartheid South Africa has also been driven by a growing
informalization of the formal sector (Rogerson, 2000). This informalization has been driven to
counter strong labour unions and to avoid regulations, tax payment and benefits (Rogerson,
2000). This informalization can also be seen in the privatization of waste management services
in South Africa where private companies employ people on short contracts and without benefits
(Miraftab, 2004).
24
It is estimated that there are 60,000-90,000 waste pickers in the informal economy in
South Africa (Godfrey et al., 2017). Their efforts account for an estimated 80-90% (by weight)
of packaging waste diverted from landfill (Godfrey et al., 2017). This estimation of the number
of waste pickers may be conservative, with some estimates being as high as 215,000 in South
Africa (Godfrey et al., 2017).
In their study, Viljoen, Blaauw, & Schenck (2016), explore numerous reasons why
people have become and remain street-pickers in South Africa. This study found that “low levels
of schooling, limited language proficiency, uncertain and low levels of income, as well as limited
access to basic social needs make it difficult for waste pickers to move upwards in the hierarchy
of the informal economy” (Viljoen et al., 2016:1). Many of the issues they encountered related to
a deprived socio-economic status including inability to finish school due to lack of money or
family issues (Viljoen at al., 2016). In the same study, of over 900 participants, Viljoen, et al.,
(2016) found that 85.7% were looking for another job, and over a third indicated that they would
take any job they could get (pg. 184). This indicates that those engaged in this kind of work face
almost no choice when it comes to their employment, and that street-waste pickers in South
Africa occupy the lower-tier of informality.
EPR schemes in South Africa rely on the informal sector for collection and return of
materials (Nahman, 2010; Godfrey et al., 2017). As will be discussed further in section 2.9 where
the REDISA plan is described, the IWPTMP in South Africa also relied on waste pickers,
referred to as micro-collectors. Micro-collectors were used to clean up the tyres disposed of in
the environment and landfills as well as remove waste tyres from locations other than tyre
dealers. In return for this work, micro-collectors were offered a small fee in exchange for each
tyre collected. This system relied on there being an abundance of people who are unemployed
25
and facing extreme poverty and therefore willing to do hard physical work for very little
compensation.
At the higher tier of informality, the REDISA plan also absorbed the network of
transporters in the informal sector who were working with waste tyres. Relationships between
tyre dealers and waste tyre transporters who collect used tyres for resale or retreading have
existed going back generations (Nkosi et al., 2013). These networks of transporters and
dealerships and the relevant knowledge these transporters possessed was absorbed into the
REDISA plan.
2.6 BEE in South Africa
Inequality in South Africa continues to be incredibly high and is related strongly to race.
Since the arrival of Europeans, White South Africans have dominated business and land
ownership (Southall, 2007). As described earlier in this chapter, this inequality was solidified
into place through policies and oppression during the apartheid period, as Black South Africans
were forced out of urban economic centers as well as the land they possessed there and were
restricted in their job opportunities and education.
Income distribution in South Africa is a useful way to understand the inequality that
existed, as White South Africans have typically earned significantly higher incomes. Towards
the end of apartheid, even as inequalities were in decline, White South Africans who made up
just 8.2% of the population received 51.9% of personal incomes (Southall, 2007: 68).
Furthermore, Black South Africans, who made up 74.9% of the population were earning just
35.7% of personal incomes (Southall, 2007: 68). In 1991 the poorest 40% of households in South
Africa earned just 3.8% of total income (Black, 2005: 1150). These statistics exemplify the
26
incredible inequality that existed in South Africa, where a minority population of White South
Africans held the majority of the financial wealth.
In an effort to address these inequalities, in 1994 the newly elected African National
Congress (ANC) made black economic empowerment one of their priorities. The ANC party
long supported the need for state intervention to create a more equitable economic system
(Cahan & van Staden, 2009). When the ANC did take power, their policies shifted towards a
more neoliberal ideology, though they continued to pursue labour-related reforms (Cahan & van
Staden, 2009). Labour unions in South Africa continue to be quite powerful, and as such, both
businesses and the government need to appeal to the concerns of labour, largely Black South
Africans (Cahan & van Staden, 2009). The strength of labour has contributed to the
implementation and development of BEE in South Africa and particularly towards the
emergence of more broad-based empowerment.
The goals of early BEE were centered around the de-racialization of business ownership
in South Africa (Tangri & Southall, 2008). Progress was made towards this goal, however, after
a decade of ANC rule, in 2005, “only five of the Johannesburg Securities Exchange (JSE) top
200 companies had black ownership of more than 51 per cent, only 27 companies had more than
25 per cent, and these 32 companies together accounted for less than 2 per cent of the JSE's
market capitalisation” (Tangri & Southall, 2008: 700). Another goal, where some progress was
made was to increase black membership on boards and in executive and senior management
roles (Black, 2005, Tangri & Southall, 2008).
Beyond deracializing business ownership and management, it was also hoped that a
redistribution of wealth could help ensure social and political stability in the country (Black,
2005). For example, it was expected that increased equality would result in the reduction of
27
crime in South Africa, which in turn could lead to an increase in investment (Black, 2005). BEE
also has the potential to increase human capital in South Africa through training and upgrading
the skills of citizens (Black, 2005).
Initial efforts towards BEE were seen to have little effect in improving the lives of
ordinary South Africans. In response to this the government shifted it’s focus to a Broad-Based
Black Economic Empowerment (BBBEE). This was put forward in the BBBEE Act, No. 53 of
2003 which created the legislative framework for the promotion of BEE in South Africa.
Under the BBBEE legislation of 2003, 7 criteria were established by which companies
BEE ranking would be established. In 2007 these were clarified in the BBBEE Codes of Good
Practice. Companies are given a score for each criterion and then an overall score is compiled.
Compliance with BEE is voluntary, and companies may choose to compensate for low scores in
some areas with higher scores another and thereby forego some actions towards BEE (Cahan &
van Staden, 2009). As listed in the Department of Trade and Industries, Background to,
Intention & Applications of the Codes of Good Practice (2007) the 7 criteria against which
companies are measured are as follows:
• Ownership – the effective ownership of the enterprise by black people
• Management Control – the effective control of the enterprise by black people
• Employment Equity – the initiatives intended to achieve equality in the
workplace
• Skills Development Element – the extent to which employers carry out
initiatives designed to develop the competencies of black people
• Preferential Procurement Element – the extent to which enterprises buy good
and services from BEE-compliant suppliers
28
• Enterprise Development Element - the extent to which enterprises carry out
initiatives aimed at contributing to socio-economic and enterprise development
• Socio-Economic Development Element - the extent to which enterprises carry
out initiatives aimed at contributing to socio-economic development and
promoting access to the economy for black people
This rating affects a company’s ranking in tender applications from the government, as
well as any sale of public entities, licensing and concessions, and public-private partnerships
entered into by government (DTI, 2007). These procurement practices were thought to benefit
mostly established formal black owned businesses, however, Rogerson (2000) has argued that
this may have also benefited black-owned micro-enterprise which operated more in the informal
sphere. This benefit is derived from a shift in government procurement and the private sector
towards working small black-owned business due to business policies of social upliftment and
community outreach (Rogerson, 2000). This is enhanced by BEE, as a company’s own
procurement practices influence their BEE scores when competing for government tenders and
this creates another layer of support for BEE business.
The policies of BEE have faced several criticisms over the years. Some have said that
because of its focus on driving economic growth, the government was not forceful enough in
setting and enforcing BEE targets (Southall, 2007; Tangri & Southall, 2008). In the post-
apartheid years, the government relied on the existing white-owned businesses to drive economic
growth and were therefore hesitant to place severe requirements on them (Tangri & Southall,
2008). There was also a fear that strict BEE legislation would deter domestic and foreign
investment in South Africa and thus impede economic development (Tangri & Southall, 2008).
The government therefore proceeded cautiously with the implementation of BEE. This also
29
draws out another criticism; that BEE policy is a detriment to the economic development of
South Africa generally. For the same reasons that the ANC feared to implement BEE to a more
extreme extent, others felt that even to the minimal extent it was implemented it harmed the
economy (Southall, 2007).
Some argue that BEE has only served to enrich an elite black class which is well
connected to the ANC (Tangri & Southall, 2008; Black, 2005). This began with voluntary action
taken by White business owners, even before the end of apartheid, who saw a need in the new
political climate to integrate more Black South Africans into their companies. However, the
political motivation of this integration meant that they sought Black South Africans who were
connected to the ANC and who could help secure preferential policies for their company in the
future (Southall, 2007). Thus, BEE materialized through “the transfer of shares, which have been
acquired disproportionately by a small number of prominent, politically connected black figures”
(Tangri & Southall, 2008: 701). It has also been argued that this black elite serve to stabilize the
relationship between the business world and the government. This in turn ensures continued
economic growth and “promotes the interests of the disadvantaged black man through job
creation and skills development” (Tangri & Southall, 2007: 713-714).
Despite these claims that the resulting economic growth will benefit all, it has been
argued that BEE has not been successful in empowering ordinary Black South Africans (Tangri
& Southall, 2007). Most Black South Africans continue to live in extreme poverty and have not
felt the benefits of BEE policies. Further, BEE seems to have done little towards job creation or
nurturing entrepreneurs (Tangri & Southall, 2007).
There are also instances of Black South Africans being put forward as having ownership
of companies, while not actually playing any role within the business (Tangri and Southall,
30
2008). This practice is referred to as fronting, and often involved someone being promised future
ownership of shares but being put forward as being a current owner for BEE purposes (Tangri
and Southall, 2008). This practice means that no economic benefit is transferred to Black South
Africans.
Despite these criticisms, BEE policies continue to be in place and to influence how South
African business are established and run. The REDISA plan can be understood as a tool of black-
economic empowerment in South Africa. The focus on job creation, and the push for the
upliftment of previously disadvantaged individuals is indicative of efforts to address the
injustices of apartheid. It is therefore important to understand the development and
implementation of BEE in South Africa to understand the REDISA plan.
2.7 Trends in Waste Management in South Africa
Waste management in South Africa developed through the apartheid, White Areas were
well serviced, but Black Areas were often neglected. Government statistics in 1995 found that
only 38% of Black South Africans had waste removed by a local authority and 20% of Black
South African households had no waste removal at all (Samson, 2009: 3). Since the end of
apartheid, local governments faced a huge challenge of extending services to all (and expanding)
populations.
South African municipalities face a severe lack of funding, and in the face of this reality
they have adopted neoliberal policies and privatized many waste management services (Samson,
2008; Miraftab 2004; Godfrey et al., 2013). Aside from cost savings, another motivation for
privatization is to avoid the burden of bureaucracy and politics which hinder decision making
within government (Godfrey et al., 2013). Municipal waste managers in South Africa are faced
with slow decision making which must pass through numerous committees, and ultimately
31
decision are made by those who lack technical expertise and are often influenced by politics
(Godfrey et al, 2013). Conversely, private companies can quickly make decisions, placing them
at an advantage (Godfrey et al., 2013).
Despite the benefits, there have been numerous negative outcomes of this privatization
including a reduced access to services, a regeneration of casual labour markets and dispossession
of the informal sector (Samson, 2008; Miraftab 2004; Godfrey et al., 2013). Firstly, where
services have been privatized, many poor South Africans have lost access as they are unable to
pay (Miraftab, 2004). Additionally, for services like waste management, privatization has meant
that communities are expected to pay for services rendered in their areas (Miraftab, 2004). This
has led to inequality in the services provided, where wealthier areas are serviced by curbside
collection while poorer areas are serviced by collection from a communal skip (Miraftab, 2004).
In some cases, privatization was driven by high labour costs, which have been protected
by strong unions in South Africa (Godfrey et al., 2013, Rogerson, 2000). Employees of private
companies are paid salaries as much as 5 times less as those in the public sector (Godfrey et al.,
2013). Privatization has also led to the casualization of labour where employees are hired on
short contracts of 1-5 years (Miraftab, 2004). In some cases, individuals, usually women, are
expected to volunteer to keep their own communities clean and have continued to volunteer in
the hopes of obtaining paid work in the future (Miraftab, 2004). This casualization of labour
around waste management has negative effects on vulnerable populations and has led to their
exploitation.
Finally, waste reclaimers3 in the informal sector have been threatened with the loss of
access to waste commodities by privatization under the neoliberal policies (Samson 2009;
3 Waste reclaimers is the term used by Samson for what are otherwise called waste pickers or waste collectors. Samson describes that “Many words are used to describe people who salvage re-useable and recyclable materials
32
Samson 2015). Samson (2015) discusses how the waste reclaimers on a dump site were the ones
who had first recognized the potential value of waste. Subsequently, the government sought to
use this knowledge for its own gain, through privatising what had once been seen simply as
waste (Samson, 2015). Specifically, to cover the cost of municipal waste services, a private
company, through government tender, sought to enclose the dump and the waste commodities
within (Samson, 2015). In this way privatization threatened to dispossess the informal waste
reclaimers working on the site not only of their livelihoods, but also of their acquired knowledge
of the value of different materials on the sites (Samson, 2015).
Given the trends within waste management in South Africa and the benefits of EPR, EPR
schemes are a fitting policy tool. EPR schemes are beneficial in that they generate their own
funding for the collection and treatment of waste. EPR schemes also avoid the bureaucratic
burdens that are faced by government run waste management systems, through easier decision
making and procurement. However, of concern is the treatment of those employed by the PRO,
as they are not protected through collective bargaining as municipal workers would be. As has
been discussed, privatization can lead to the casualization of labour and the further
marginalization of already vulnerable groups. Another potential problem is that PROs might lead
to the exclusion of some who are already working with the waste in question. Workers in the
informal sector who are not operating under the new regulations defined by the industry waste
management plan may see their livelihood threatened.
from the waste-stream. As will be discussed below, words such as 'scavenger' are seen as derogatory and rejected by the people who do this work. Although the commonly used term 'waste picker' is not necessarily derogatory, it does not capture the nature or importance of the labour being performed. The term 'recycler' is too narrow as not all goods salvaged are recycled. I prefer the term 'reclaimer' as it emphasises that, through their labour, people are reclaiming items cast aside by others, and are also reviving dead commodities and reclaiming the value inherent within.” (Samson 2015: 21)
33
Other than the EPR schemes for waste tyres discussed in this research, there are 4 EPR
schemes currently operating in the South African waste management industry. These are for
plastics bags, cans, bottles, and polyethylene terephthalate (PET) plastics (Nahman 2010). Of
these only that for plastic bags was imposed through government legislation, with the others
being voluntarily led by industry. The industry led initiatives have signed memorandums of
understanding with the government, whereby if they continue to recover a percentage of the
waste they generate, the government will not impose legislation (Nahman 2010). These
voluntary EPR schemes rely on a deposit-refund model and industry has taken responsibility for
recycling the materials, as well as opening collection points (Nahman, 2010). The EPR schemes
rely primarily on the informal sector for collection and return of materials and have no formal
mechanisms in place (Nahman, 2010). These systems have been successful at recovering large
portions of their respective waste stream. In the case for cans 67.5% are recovered, which is one
of the highest recovery rates in the world (Nahman, 2010).
When considering the introduction of a levy to fund EPR in South Africa, it is important
to understand the feasibility of economic instruments in the country. In a study of the use of
economic instruments for solid waste management in South Africa, Godfrey & Nahman (2009),
found that they “tend to be ineffective because they are typically used for cost-recovery or
revenue-raising purposes, rather than as incentives for changing behaviour” (pg. 523). As an
example, of the amounts recovered through the levy charged under the plastic bag EPR scheme
only 7% was allocated towards the recycling of plastic bags with the vast majority being
absorbed into the general government funds (Nahman 2010). While the viability of plastic bag
recycling is also a factor, there has been no evidence of any improvement in the recovery of
plastic bags since the introduction of the levy in 2003 (Godfrey & Nahman, 2009). This calls into
34
question how funds collected by government in the name of waste management will be
distributed and used. Godfrey & Nahman (2009) also highlighted a need to consider a lack of
monitoring and enforcement in South Africa which could led to illegal dumping and undermine
the effectiveness of some economic instruments.
Godfrey and Oelofse (2017) have identified the EPR scheme for waste tyres as the start
of “the Drive for EPR” in government waste management policy in South Africa (pg. 63). The
Department of Environmental Affairs has recognized that waste and recycling are promising
areas for job growth, and it is motivating their drive for EPR schemes in South Africa (Godfrey
et al, 2017). The government has recently called for industry to submit plans for the management
of paper and packaging, waste electrical and electronic equipment (WEEE) and lighting. Some
of these waste streams already have industry led initiatives in place and this calls into question
how the new government legislated plans will work with the existing programs and what the
impact will be for those currently working under the schemes.
2.8 Legislative Context
An overview of the legislative development of waste management in South Africa can be
found in Godfrey and Oelofse (2017), Historical Review of Waste Management and Recycling in
South Africa. South Africa has extensive laws, which govern waste management. These laws set
the broader environmental goals for the country as well as specify how waste should be stored,
transported, and handled. Environmental goals in South Africa are often closely associated with
goals of economic and social development (Godfrey & Oelofse, 2007). This is evident in the
earliest legislation around the environment, as well as the legislation around waste tyre
management.
As set out in Section 24 of the South African constitution (1996): everyone has the right
35
a) to an environment that is not harmful to their health or wellbeing; and
b) to have the environment protected, for the benefit of present and future generations,
through reasonable legislative and other measures that—
i) prevent pollution and ecological degradation;
ii) promote conservation; and
iii) secure ecologically sustainable development and use of natural resources while
promoting justifiable economic and social development.
This section of the constitution underpins the need to prevent pollution of the environment,
which in relation to tyres would mean to minimize illegal dumping and burning for steel
recovery. Additionally, if we consider waste tyres to be a resource, there is a need to promote
economic and social development through their use.
An earlier document that governed waste management in South Africa was the
Environmental Conservation Act (ECA) (Act 73 of 1989, as amended). The ECA defined waste
as well as setting out requirements for waste management (Godfrey & Oelofse, 2017). The ECA
did not extensively cover the issues of waste management but focused on preventing negative
environmental impacts arising from poor landfilling practices (Godfrey & Oelofse, 2017). The
ECA also acknowledged that regulations for the reduction, reuse and recovery of waste could be
introduced, but this provision was never used (Godfrey & Oelofse, 2017).
The National Environmental Management Act (NEMA) of 1998 originally set out the
legal framework for integrating good environmental management into development activities in
South Africa. NEMA brought the waste hierarchy of avoid, minimize, re-use, recycle and finally
dispose of in a responsible manner (RSA, 1998). Within this Act is also the framework for
establishing legislation around Environmental Impact Assessments which is a requirement for
36
waste tyre processors. It also “introduced a number of additional guiding principles into South
African environmental legislation, including the life-cycle approach to waste management,
producer responsibility, the precautionary principle and the polluter pays principle” (NWMS
Research: 6). These principles underpin EPR and this can be seen as a first step towards that
eventuality.
The National Environmental Management: Waste Act (NEMWA) which was passed in
2008 currently regulates waste management. In South Africa, provincial governments have
jurisdiction over the environment and pollution and local governments have jurisdiction over
matters of cleansing and refuse removal, refuse dumps and solid waste disposal (RSA, 2012).
NEMWA provides for national norms and standards relating to these matters (RSA, 2012). This
act outlines the need for a National Waste Management Strategy for South Africa, as well as the
legal framework for the development of waste management, licensing and enforcement for waste
(RSA, 2008).
At section 28, NEMWA gives government the right to call for industry waste
management plans (IWMP) for any waste generated which affects more than one province in
South Africa (RSA, 2008). NEMWA also sets out the procedure for the preparation, contents and
review of these IWMPs (RSA, 2008). Through these provisions the NEWMA created a legal
environment in which existing voluntary EPR schemes could become mandatory as well as for
the development of new EPR schemes (Godfrey & Oelofse, 2017). Further in NEMWA the duty
of care provision is used when “obliging holders of waste to take reasonable measures to
implement the waste hierarchy whilst protecting the environment and public health” (NWMS
Research). This duty of care is significant when considering historical waste tyre stockpiles, and
37
this was actualized through the REDISA plan where owners of stockpiles were required to
submit waste tyre stockpile abatement plans (REDISA, 2012).
Closely following the NEMWA, in 2009 the government passed the Waste Tyre
Regulations. These regulations were subsequently amended in 2016 before being repealed with
the passing of the Waste Tyre Regulations, 2017. The 2009 Regulations were the ones in place
when the REDISA plan was prepared and passed through government. The 2009 Waste Tyre
Regulations, set out the duties of tyre producers, tyre dealers, and stockpile owners in relation to
waste tyres, as well as the requirements for the storage sites for waste tyres (RSA, 2009).
Additionally, the 2009 Regulations describe the requirements of an integrated industry waste tyre
management plan (IIWTMP) which was closely aligned with NEMWA and stipulated the
contents of such a plan. Of interest to this research are the requirements that any integrated
industry waste tyre management plan must at least:
(n) provide details of the manner in which previously disadvantaged individuals will be
integrated into the implementation of the integrated industrial waste lyre management
plan;
(o) indicate how job creation, training and development will be realised in the industry;
(RSA, 2009)
While these are 2 of 20 requirements of an IWMP, they demonstrate that the emphasis on job
creation, that is so notable in the REDISA plan, was present in the legislation as well.
Subsequent to the legislation of the REDISA plan in 2012, the Department of
Environmental Affairs has made numerous revisions and additions to the legislation that governs
waste management, and in particular IWMPs. These additions include the creation of the Waste
Management Bureau (Waste Bureau) which was established through the NEMWA Amendment
38
of 2014 (RSA, 2014). The Waste Bureau was not operationalized until 2017 (DEA, 2017b). The
Waste Bureau is a branch within the DEA and one of its primary duties is to oversee the IWMPs,
as well as to support other government initiatives around waste (DEA, 2017a). The Waste
Bureau has also been charged with managing the IIWTMP after REDISA was ordered liquidated
by the courts (PCEA, 2017). By having the Waste Bureau oversee any future IWMPs this
legislation has added a level of oversight that did not exist when the REDISA plan was
introduced.
In 2016 the DEA also legislated a National Pricing Strategy for Waste Management
(NPSWM), which was a requirement of NEMWA. As described in the policy, “this strategy
contains guiding methodologies for the setting of waste management charges, aimed at funding
the re-use, recycling or recovery of waste” (RSA, 2016). The NPSWM notably also required that
except for deposit refund model, upstream EPR fees should be collect through South African
Revenue Service (SARS) and transferred to the National Treasury (RSA, 2016). In order to
receive the funds for the management of the plan, a business plan must be submitted as
motivation to the National Treasury to fund the waste management activities (RSA, 2016).
Another piece of legislation that has the potential to influence waste tyre management in
the future is the Carbon Tax Bill. The Carbon Tax is set to be implemented in 2019, although its
implementation has been delayed in the past and this date is still not confirmed (Sweet, 2018).
When it comes into effect this legislation will impose a tax on greenhouse gas emitting fuels
(Sweet, 2018). Although waste to energy fuels will be taxed, if their emissions are lower it could
drive the market for waste-to-energy technologies in South Africa, as well as waste derived fuels
containing waste tyres.
39
There are also policies around economic and social development that have influenced the
development of waste tyre management in South Africa. These policies include the BBBEE
legislation discussed in section 2.6 and the National Development Plan. The National
Development Plan includes a goal to create 1 million jobs in South Africa before 2030 (RSA &
NPC, 2012). This goal likely influenced the push for job creation in waste management policy in
South Africa and the REDISA plan.
2.9 The REDISA Plan
The Waste Tyre Regulation of 2009 called on industry to submit Integrated Industry
Waste Tyre Management Plans (IIWTMPs). Under the legislation, plans could be submitted by
any person, category of person or industry (NEWMA, 2008). Of those submitted, only 3 made it
through initial screening being The South African Tyre Recycling Programme (SATRP) plan,
The Retail Motor Industry Association (RMI) plan and The Recycling and Economic
Development Initiative of South Africa (REDISA) (Nkosi et al, 2013).
In the Waste Tyre Regulations there was a provision that would have allowed for
multiple plans as any producer may prepare and submit an IIWTMP for approval by the Minister
or register with an existing IIWTMP (RSA, 2009). Despite this the REDISA plan was the only
one approved by the DEA. At the outset of the REDISA plan they made numerous arguments as
to why there should be only one plan. These arguments focused on maintaining simplicity for
those working under the plan, as well as effectiveness of the implementation, operation and
monitoring of the plan (REDISA, 2012). Due to the single PRO approach taken by the
government, all tyre producers and importers were obligated to register with the REDISA plan
(DEA, 2012).
40
Following the passing of the REDISA plan in November 2012, the DEA and the
REDISA plan faced several legal challenges from the proponents of the other plans SATRP and
RMI (DEA, 2013). These challenges centered around whether the Minister had adhered to the
legislation and gone through the proper processes of consultation prior to approving the REDISA
plan. Ultimately these challenges were decided against in the courts, but they did delay the start
of the plan until June 2013 (PCEA, 2017).
2.9.1 Substance of the REDISA Plan
Under the plan, producers and importers were required to pay a fee to the PRO based on
the weight of tyres sold. The levy rates were standardized based on average weights of each tyre
size. These averages were calculated based on reported figures from producers and were subject
to review annually. The fee was set a 2.30 Rand/kg, and the allocation of those funds were
divided as shown in Table 2.
Allocation Percentage Cents/Kg
Transportation 38.0 0.88
Administration 20.0 0.46
Depots 19.5 0.43
Recycler/Cement Kiln 13.5 0.31
Social Upliftment 3.5 0.08
Research & Development 2.5 0.06
Marketing 2.0 0.05
Training 1.0 0.03
Total: 100 2.30
Table 2: Allocation of Tyre Levy Fee as per REDISA, 2012
The REDISA plan is based on a waste tyre hierarchy, which follows the common levels
of reduce, re-use, recycle, recover. This hierarchy is based on the one introduced into South
African legislation through the NEMA of 1999. At the first level the plan hopes to avoid the
creation of waste tyres through public education around tyre care. Secondly, the REDISA plan
was to encourage re-use of tyres through tyre retreading. The REDISA plan recognized that tyre
41
retreading in South Africa is “less common than it could be” (REDISA, 2012: 16). REDISA
undertook to assess the retreading industry, collaborate to set quality assurance standards around
retreading, promote the use of retread tyres and fund research about retread tyres. However,
REDISA stated that they would not subsidize tyre retreading.
The third level of the hierarchy is recycling, and the REDISA plan recognized crumbing,
pyrolysis and cryogenic processing as recycling options. The plan stated that REDISA would
assist these businesses through training, financial support and mentoring and that business
development will be focus of BEE entrepreneurs. Additionally, the REDISA plan pledged to
support researchers to develop technologies suited to South Africa and increase expertise in the
country. The lowest level of the hierarchy is recover and in the case of waste tyres is focused on
energy recovery such as processing in cement kilns. The plan does not address how it will
implement this level of the hierarchy aside from stating that any subsidy would be assessed
independently for each energy recovery facility.
In an effort to include participants from diverse backgrounds, REDISA plan established
an adjudication process for the selection of actors for various roles funded under the plan. The
adjudication process described in the plan was based on the following criteria: BBE status,
financial proposal, ability to execute, competencies, size (preference to small) and area of
operation (preference to local) (REDISA, 2012: 14). For each type of actor working under the
plan there were some additional criteria applied in their contract award/tender process. These
criteria were in line with the plans goals to drive employment generation of previously
disadvantage individuals, promote BEE and drive the creation of Small, Medium and Micro
Enterprise (SMME). The REDISA plan also called for the inclusion of actors from the informal
sector, recognizing that prior to the plan they handled up to 75% of scrap tyres (REDISA, 2012).
42
2.9.2 Waste Tyre System under the REDISA Plan
Figure 1 illustrates the waste tyre system as it operated under the REDISA plan.
Figure 1: The Waste Tyre System in South Africa
Under the REDISA plan, new depots dedicated only to waste tyres were established
throughout the country. These were established through incubation processes by REDISA,
whereby depots were established with management support from REDISA, and were to be
release to the operating company once they were sustainable (iSolveit, 2017). According to the
iSolveit (2017) auditing report, none of the depots has been released from the incubation process
by 2016. These depots had independent managers, but they were funded by REDISA and
supported for various business needs, including provisioning of equipment and some services
and maintaining the leases for depot properties. The depots would only accept tyres from
registered tyre transporters. In some cases, REDISA purchased pre-processing equipment for
depots including tyre bailers and shredders. Later, as depots became full, REDISA opened
holding depots in which tyres were stockpiled until more processing capacity was created.
43
Any tyre transporter moving waste tyres was required to register under the plan. Tyre
transporters were also required to be registered with SARS and have a driver’s license, insurance
and a bank account into which to receive their pay (REDISA, 2012). Primary transporters were
allocated dealerships and micro-depots from which to collect and were not allowed to collect
from other locations. Likewise, secondary transporters were allocated deliveries to processors,
other depots and exporting facilities.
In the original plan there was no mention of micro-collectors, although they ended up
playing a significant role in waste tyre system. In the plan an unregistered tyre transporter is
discussed in a similar role. It was anticipated that unregistered transporters would be in the
informal sector and that they would likely supply tyres to registered transporters (REDISA,
2012). As written in the plan these unregistered transporters would have been allowed to deliver
tyres to any depot as long as they could accept electronic payment and remained within a
monthly quota of collected tyres (REDISA, 2012). Through the implementation of the plan this
is not how micro-collection was carried out; instead, only registered transporters were allowed to
take tyres to depots and micro-depots were established for micro-collectors.
While micro-collectors and micro-depots were not conceived of in the REDISA plan,
they were later established. A micro-depot was a shipping container which was located nearer to
micro-collectors than depots and were managed by an administrator for a monthly fee. Micro-
collectors had to register with REDISA and were provided with an eWallet card through which
they could be paid (REDISA, n.d.). While this is similar to what was proposed as an unregistered
tyre transporter in the REDISA plan, it is important to note that under the REDISA plan the
projection of jobs to be created excluded “any estimate of number of informal collectors”
44
(REDISA, 2012: 28). The role of micro-collector was not a position in which REDISA had
planned to create jobs but was added after the implementation of the plan.
The REDISA plan also described how processors would be selected and supported. Each
processor operating in the waste tyre system negotiated a unique contract with REDISA
(REDISA, 2012). While there was a 310 rand per ton allocation for processors in the REDISA
plan, not all processors were paid this amount (REDISA, 2012). Similar to the program for
depots, REDISA also sought to incubate processors through helping entrepreneurs establish
businesses (REDISA, 2012). This program is not explained in much detail in the REDISA plan,
however, it is stated that processors will be primarily BBBEE entrepreneurs and that “REDISA
will assist in establishing these businesses through training, financial support and mentoring”
(REDISA, 2012: 13).
As seen in the diagram above, there continues to be a movement of waste tyres outside of
the REDISA waste tyre system and this will be discussed further throughout this study.
2.9.3 Issues with the Implementation of the REDISA Plan
Targets for collection, recycling or waste-to-energy were not included in the REDISA
plan and therefore it is difficult to assess how well the plan operated. Targets were later
determined between REDISA and the DEA though reporting on these targets is unclear
(Parliament of RSA, 2018; REDISA, 2015a). As per REDISA’s 2015 Annual Report they
diverted 32% of waste tyres from landfill. Additionally, they report having increased tyre
recycling from 4% to 18% (REDISA, 2015a). REDISA was later criticized for including
exported tyres within the recycling rates and it is unclear if exports were included in the number
cited above (iSolveit, 2017). Targets for job creation will be discussed in the results chapter of
this study at Section 4.4.
45
One significant change in legislation that occurred during the years that REDISA was
running was the introduction of the National Pricing Strategy for Waste Management. This
changed the way in which fees or levies were to be collected under EPR schemes in South Africa
(RSA, 2016). Instead of the levies being paid directly to the PRO, they were instead to be paid to
SARS and then distributed to the PRO through the Waste Bureau (RSA, 2016). Dispersal of
funds from the National Treasury and the Waste Bureau depended on the PRO, in this case
REDISA, to submit a business plan to the DEA (RSA, 2016). On February 1, 2017, this came
into effect and REDISA did not receive any levies for tyres produced or imported after that date
(MEA v REDISA, 2017). REDISA did not submit such a business plan, and therefore did not
receive any funds from its operation (PCEA, 2017). As such in June 2017 REDISA was forced to
discontinue the collection of tyres and cease operations.
Prior to this change in legislation, there were concerns about possible mismanagement of
funds by REDISA’s management. A senior official at the DEA described that REDISA
“obfuscated, failed to cooperate and withheld crucial information from the DEA” (PCEA, 2017)
These concerns were brought to public attention by an episode of the television show, Carte
Blanche in November 2015 (Mathews, 2017). While this episode has since been removed from
Carte Blanches website, based on other news reports it raised questions around the lack of jobs
created, excessive spending including on the private residence of management and their salaries
and tyres being exported rather than processed in South Africa (Comrie, 2018; Mathews, 2017).
In 2016, the DEA requested a performance review that was conducted by an external auditor,
iSolveit which, following REDISA’s challenge of its veracity, was then reviewed by Ernst and
Young (PCEA, 2017).
46
2.9.4 Current State of the REDISA Plan
In June 2017 the Minister of Environmental Affairs brought legal applications against
REDISA seeking to have it placed into final liquidation, which would halt them from doing
business and sell off their assets (MEA v REDISA, 2017). This application was brought based on
the “dissatisfaction with REDISA in terms of transparency, inadequate reporting on the plans, as
well as suspicion around failure to meet set targets in the plan” (PCEA, 2017). There were
additional concerns over the REDISA reports of their rapidly diminishing financial reserves, and
the Minister acted to protect the public funds (PCEA, 2017). On September 15th, 2017 the court
ordered that REDISA be liquidated, however, REDISA has since appealed the decision and the
appeal has not yet been decided (PCEA, 2017).
Subsequently, the DEA, through the newly established Waste Bureau took over
management of the plan. They began operations in Sep-Oct 2017 and quickly entered into new
contracts with operators working at all levels of the REDISA plan (PCEA, 2017). Since that
time, the Waste Bureau has been managing the REDISA plan in order to maintain the collection,
storage and processing of waste tyres. One of the first things that the Waste Bureau did was to
increase pay for both micro-collectors and transporters (DEA, 2018a). Micro-collectors saw an
increase from 4 to 6 rand per tyre and the quota of tyres they are allowed to deliver each month
increase from 750 to 1000 (DEA, 2018a). Transporters saw their individual rates for tyre
deliveries increase by 12% (DEA, 2018a). In December 2017 the Minister again put out a call to
industry and requested that new IIWTMP be submitted (RSA, 2017). The process of selecting a
new plan for the management of waste tyres is currently underway.
47
2.10 Waste Tyre EPR Case Studies
South Africa is one of many countries to have implemented an EPR scheme for waste
tyre management. Globally, there have been numerous case studies done with regards to
different instruments for end-of-life tyre management including in Portugal (Ferrão et al., 2008),
Brazil (Milanez & Bührs, 2009), Turkey (Karaağaç et al., 2017), Spain (Uruburu et al., 2013),
and Thailand (Jacob et al., 2014). While the context for the implementation for EPR is different
in every country, in order to better understand the instruments available, it is important to review
some cases of how EPR schemes for waste tyres have been implemented. This is particularly
important in the South Africa context where REDISA was often praised for being the first plan
of its kind, but really followed a typical structure of EPR schemes globally.
In their study of end-of-life tyre management in Portugal, Ferrão et al. (2008) describe
the establishment of an EPR scheme very similar to that established in South Africa. The law
placed responsibility for end-of-life tyres on the producers and suggested the establishment of a
PRO to manage waste tyres (Ferrão et al., 2008). Similar to REDISA, the PRO was asked to set
the necessary fee subject to government approval, set up the collection network for waste tyres
and establish contracts with retreaders, recyclers and any other entities responsible for end-of-life
tyre activities. In Portugal the disposal targets for waste tyres were defined by law and set targets
for 95% of EOL tyres to be collected, 30% retreaded, and the remaining recovered tyres be
incinerated or recycled, with at least 65% of those tyres being recycled (Ferrão et al., 2008). It
should be noted that the tyre retreading industry in Portugal was well established prior to the
EPR schemes and there were existing incinerators and recyclers as well. The establishment of
the PRO differed from that of REDISA in that the stakeholders were the producers, retreaders,
48
and rubber industrials, who through their representative organizations held 60%, 20% and 20%
of the shares respectively (Ferrão et al., 2008).
The implementation of waste tyre management by the Portuguese PRO, Valorpneu also
differed in some ways from that of REDISA. Similar to the REDISA plan, dealers were expected
to accept old tyres from consumers when new tyres were purchased, however, they were also
responsible for transporting waste tyres to collection points (Ferrão et al., 2008). While
collection points were contracted by Valorpneu, they were paid based on a price per ton of tyres
when those tyres were distributed to processors (Ferrão et al., 2008). Similar to REDISA,
Valorpneu was responsible for the cost of transporting tyres to processors, as well as the
negotiated fee per ton paid to each processor for recycling or incinerating (Ferrão et al., 2008).
Valorpneu was also directly responsible for processing legacy waste tyre stockpiles which
existed throughout Portugal, however the estimated volumes were only 30,000 tonnes which is
significantly less than what is estimated to exist in South Africa (Ferrão et al., 2008).
The plan in Portugal took into consideration existing actors, such as the already
developed retreading businesses. Retreaders were allowed to access tyres from waste tyre
collection facilities; however, they were required to purchase tyres and transport them on their
own (Ferrão et al., 2008). This process sought to keep in place the market system that already
existed for tyre retreading, while also increasing access to retreadable tyres (Ferrão et al., 2008).
The EPR system that was put in place benefitted the existing recyclers which were reportedly
near closing prior to the legislation (Ferrão et al., 2008). While the PRO negotiated a different
fee for each processor, the desire to increase the proportion of processing through materials
recovery vs. incineration seems to have benefited recyclers (Ferrão et al., 2008).
49
In Turkey, waste tyre management operates under EPR principals. There is a quota
system in place whereby producers are responsible for the recovery of a proportion of waste
tyres based on inputs into the system from the previous year (Karaağaç et al., 2017). The quota
starts at 30% for the first year of implementation and then increases by 5% for the next 4 years
(Karaağaç et al, 2017). Following that 5-year period the quota would be determined based on the
average annual production (Karaağaç et al, 2017). A PRO, the Tyre Industrialists Association
(LASDER), was established in collaboration between the government and the major tyre
producers. This organization was then tasked with the collection, transportation, storage and
distribution of waste tyres to producers (Karaağaç et al, 2017). The PRO in Turkey has been
failing to meet its collection targets and has identified the problem as being too few processors
who are accepting end-of-life tyres (Karaağaç et al, 2017). The amount of materials recovery and
cement kiln processing increased between 2007 and 2010. As of 2010, over 50% of tyres being
collected in Turkey are being processed in cement kilns (Karaağaç et al, 2017). Turkeys
experience highlights the need to develop a tyre processing market in order for tyre collection to
be sustainable.
The study in Brazil analyzed the constraints of an EPR scheme for waste tyres in a
similarly developed country to South Africa. The EPR scheme in Brazil was formed on the basis
of an agreement between the government and tyre producers and importers (Milanez & Bührs,
2009). Under the agreement tyre producers and tyre waste importers were separately responsible
for processing a percentage of the tyres they produced/imported (Milanez & Bührs, 2009).
Within 4 years of the introduction of the plan, these targets were set in excess of 100% to
encourage collection of historical stockpiles (Milanez & Bührs, 2009). There existed a strong
market for remoulded tyres and despite it being illegal under the plan importers of waste tyres
50
received a court injunction to continue importing waste tyres (Milanez & Bührs, 2009). Due to
the allowance to import tyres, it is thought that these importers met their obligation under the
agreement through the processing of imported tyres from Europe (Milanez & Bührs, 2009).
Subsequent to the introduction of the plan, waste tyre imports increased from 1.2 million units to
7.0 million units (Milanez & Bührs, 2009). In 2005 the tyres importers stated that “the number of
tyres destroyed was equivalent to their total obligation for then following 10 years” (Milanez &
Bührs, 2009).
Because there was no stipulation as to how waste tyres were processed, most were burnt
in cement kilns (Milanez & Bührs, 2009). Producer and importers did not invest in developing
other technologies for the disposal of waste tyres (Milanez & Bührs, 2009). Furthermore, they
did not modify their products to reduce environmental impacts (Milanez & Bührs, 2009).
Producers and importers also weren’t forced to spend money on the establishment of collection
facilities as most of these were set up in collaboration with municipal governments (Milanez &
Bührs, 2009. This removed the potential benefit of shifting the cost of waste tyre management
off municipalities, as well as the potential benefits of developing processing capacity or tyre
redesign. The authors blame the lack of these benefits on the insufficient knowledge of
government entities negotiating the agreement (Milanez & Bührs, 2009). This serves to
demonstrate the importance of setting targets that distinguish between collection, recycling and
waste-to-energy processing as was identified by Fishbein (2002) as a requirement for a
successful EPR plan.
The Brazilian government also lacked the capacity to monitor and enforce the agreement
(Milanez & Bührs, 2009). While it was a federal regulation, they did not have any officers to
monitor the implementation and were unable to solicit support for state environmental authorities
51
(Milanez & Bührs, 2009). The agreement therefore relied on reporting of the producers and
importers and had no capacity to challenge their reporting (Milanez & Bührs, 2009). Especially
in the context of developing countries where institutional capacity tends to be weaker, a plan
needs to consider how government will monitor and evaluate the implementation of EPR.
A 2014 study about waste tyres in Thailand described how there is little government
intervention in waste tyres management (Jacob et al., 2014). The result is that some 44% of
waste tyres still end up in the open environment (Jacob et al., 2014). The incineration and
recycling that does occur is carried out by private firms in a free market (Jacob et al., 2014).
Waste tyre processing in the private sector is done primarily by pyrolysis plants, and cement
kilns with less than 10% of tyres being resold as second-hand tyres, retreaded or recycled (Jacob
et al., 2014). It is interesting to note that despite no government legislation around the
management of waste tyres, a significant portion of the tyres are still being diverted into a market
for waste tyres.
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Chapter 3 – Methods
3.1 Study Areas
My research was carried out in Western Cape and Gauteng provinces in South Africa.
Additional participants were recruited from KwaZulu-Natal and North West provinces and
interviewed remotely. Western Cape province was chosen as my first location for research
because in 2005, what was understood to be the first industrial tyre recycling plant, operated by
SA Tyre Recyclers, was opened in this region (Nkosi et al., 2013). Because of the presence of
this recycler, I anticipated that I would have access to people at all levels of the waste tyre
system, as well as actors who were working with tyres prior to the REDISA plan. Despite
speaking to actors from all aspects of the waste tyre system in Western Cape, I was not able to
recruit a sufficient number of participants. Gauteng province was selected as a secondary site for
research because as it is the industrial center of the country, there is an abundance of actors in the
waste tyres system in this region. I also had some contact information for potential participants in
Gauteng which I had received through interviews conducted in the Western Cape. Additionally, I
anticipated recruiting participants from the Waste Bureau which is located in Pretoria, Gauteng.
In an effort to reach as many potential participants as possible, additional contacts were made in
KwaZulu-Natal and North West provinces and interviews were conducted via Skype.
3.2 Participant Recruitment
I had originally planned to identify participants through the South African Waste
Information System (SAWIS) which is a government database used to track the volumes of
waste created, transported and recycled. I did consult the SAWIS database; however, records
were inconsistent, out of date and did not always include contact information. Moreover, I was
unable to identify those working specifically with waste tyres. I chose not to contact the Waste
53
Bureau directly to request contact information of those working with waste tyres. I made this
decision based on reading about the proponents of a proposed waste tyre management plan trying
to obtain this information to consult the tyre industry and being denied access to contact
information by the Waste Bureau for confidentiality reasons (TWAMISA, 2017).
Due to the inability to use these databases to find participants, I identified participants
primarily through a snowball sampling method. Some initial contacts were made through NGOs
and internet searches and then, during each interview, participants were asked if they were
willing to provide contact information for other potential participants. In some cases, I requested
specific information for certain individuals or roles within the waste tyres system.
To track who had been contacted, as well as what responses I received I maintained a
“diary” of phones call, emails and personal contacts made throughout my research process. In
this document I tracked the dates of interactions, as well as kept track of how people were
contacted. Where I received a negative response of someone unwilling to participate in my
research this was also recorded. If people gave a reason for not participating, or any relevant
information, this was also recorded in this diary. The most common “refusal” was a lack of
response to my emails or phone calls. Refusals that I did receive were largely because people did
not work with waste tyres and therefore did not feel they had knowledge to contribute.
Where I had email addresses for participants, they were contacted first by email, that
included a brief description of my motivation for their participation and attached an invitation to
participate in my research. The invitation to participate was the same for all contacts and is
attached at Appendix A. If I did not receive a reply to my email, I would then follow-up with a
phone call.
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For many contacts I only had a telephone number as contact information. Generally, I
also found that telephone calls were more effective for getting a response from potential
participants as many of my emails went unanswered. Because of these factors most participants
were contacted initially by phone, and this made it more difficult to completely explain the
motivation for my research and their participation prior to the interview.
Whenever possible, prior to the interview a consent form was sent to participants for
them to review. A copy of the consent form is attached as Appendix B. Where I only contacted
people by phone prior to the interviews, a consent form was presented to them at the outset of
our meeting. I would briefly explain the consent form, outlining that the research was being done
for the master’s thesis, that they were participating voluntarily, and that their identity would be
kept confidential and all data destroyed after two years. Participants were also given time to
review the consent form before signing. I verbally confirmed with each participant that it was
okay to record our discussion prior to starting the audio recording. Each interview participant
was offered a copy of the consent form to keep for their records. For interviews which were done
by Skype, all participants were sent a consent form by email prior to the interview and asked to
return a signed copy.
3.3 Interview Participants
Research participants were sought from all sectors of the tyre system. This broad range of
participants was needed to gain a more holistic understanding of how REDISA has changed the
waste tyre system. Actors within the waste tyre system include: processors, depot workers,
transporters, micro-collectors, secondary industry, tyre retreaders, tyre dealers, REDISA
management, Waste Bureau management, waste management companies and tyre stakeholders.
A description of these actors is provided in Table 3.
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Participant
Category
Description Number of
Participants
Processors • those who use waste tyres as a resource for
their business.
• Ex. rubber crumbing businesses, tyre
pyrolysis and cement kilns
9
Depot Workers • those who worked at or managed REDISA
funded waste tyre depots
• some depots also carried our pre-processing
functions (ex. bailing/shredding)
4
Transporters • primary: those who collect tyres from
dealerships and micro-collectors and deliver
them to depots
• secondary: those who move tyres from the
depots, either to other depots or to processors
6
Micro-
Collectors • those who collect tyres either in the
community, from informal (often second-
hand) tyres dealers, as well as those who
collect in landfill sites
4
Secondary
Industry • those who use waste tyres to manufacture
various items including, playground
equipment, furniture, shoe soles, planters and
animal feeders
Not
interviewed
Tyre Retreader • those who retread used tyres for resale
• primarily done to truck tyres, although all
tyres can be retreaded
1 – also tyre
dealer
Tyre Dealers • those who sell tyres both in the formal and
informal economy
• includes the sale of new and used tyres
2
REDISA
Management • those who were involved in the management
and implementation of the plan.
3
Waste Bureau • Branch of the Department of Environmental
Affairs
• took over management of the waste tyre plan
from REDISA
Not
interviewed
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Waste
Management
Companies
• not directly involved with waste tyres
• private companies who manage the
collection, recycling and disposal of various
waste streams in SA
4
Tyre
Stakeholders • those who are not directly involved with
waste tyres but who had knowledge of waste
tyre management in SA
1
Total: 33
Table 3: Description of Interview Participants
In all I interviewed 33 participants. Of those participants 9 were processors, 4 were depot
workers, 6 were transporters, 2 were dealers, 4 were micro-collectors, 3 were from REDISA
management, 4 from waste management companies and 1 tyre stakeholder. Some interview
participants currently have or had experience in different roles within the waste tyre system. For
simplicity, I have included them in the category which best describes the work that they do, but
there were instances where they spoke to other roles within their interviews. Below I will
describe the recruitment of each category of participant as well as provide further details about
participant’s roles within each category. Where appropriate I will provide the total number of
operators in each category as reported by the Waste Bureau in March 2018.
The Waste Bureau identified 12 tyre processors, of which 9 were active (DEA, 2018a).
There are processors in the informal sector that exist outside these numbers who do not receive
tyres through the waste tyre management plan. Processors were identified through internet
searches, other participants and contacts received from an NGO. There were 9 tyre processors
who participated, 3 were involved with rubber crumbing, 3 were involved with pyrolysis and 3
were from cement kilns which were using tyres as a substitute fuel. Processors were from 7
different companies. One participant would not have been counted in the Waste Bureau numbers
but is operating in the informal sector.
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The number of depots operating continues to increase to meet the demand for tyre storage
and there are now some depots where tyres are only stored and not accepted or dispersed. In
March 2018, there were 19 depots identified by the Waste Bureau (DEA, 2018a). Contacts for
depot workers were received through internet searches and other participants There were 4
participants from depots of which three were depots managers and one was a depot
administrator. All 4 participants were from different depots.
There are 74 tyre transporters enterprises operating with the waste tyre system (DEA,
2018a). Of those only 10 are doing secondary transport where waste tyres are moved from the
depots to processors or other depots. The remainder are primary transporters and collect waste
tyres from dealers and bring them to the depots. Some transporters were identified through other
interview participants. As an additional way to recruit waste tyre transporters I visited numerous
tyre dealerships that were able to provide contact information for those who collected their tyres.
Of the 6 waste tyre transporters who participated, only one was working in secondary
transportation. That participant also had previous experience working as a primary transporter.
Micro-collectors were contacted through an NGO as well as through obtaining
information from other participants. Micro-collectors were the most difficult participants to
recruit due to the informality of their work. Only 4 participants were recruited despite there being
the highest numbers of micro-collectors reported to be working by the Waste Bureau with 206
registered (DEA, 2018a). Of those interviewed, one participant, who worked both at a landfill
site and as a street picker, was not collecting tyres however she had been approached by
REDISA and considered working under the plan. The remaining three were collecting tyres, one
worked at a landfill site, and one worked in the community and one was a depot manager.
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I did not seek any participants working in the secondary industry. The secondary industry
includes artisans who use tyres to manufacture various items including, playground equipment,
furniture, shoe soles, planters and animal feeders. Two tyre transporters were also involved with
the secondary industry, one formerly and one currently. Through my study, I also heard some
mention of interaction between secondary industry and REDISA depots whereby secondary
industry procured tyres from the depots. In terms of processing tyres, the secondary industry
does not use a large volume of tyres. However, due to the artisanal nature of the work, it does
have good potential for job creation. While secondary industry is mentioned in the REDISA
plan, to my understanding they had not yet sought to generate any additional jobs in the
secondary industry. Additionally, due to the abundance of tyres still available in South Africa, it
was not anticipated that the REDISA plan affected these actors’ ability to access tyres.
Therefore, I assumed that the secondary industry had not been impacted significantly by the
REDISA plan and I did not interview these actors for my study.
As is true globally, tyre retreaders are no longer common in South Africa (ERTMA,
2015; Uruburu et al, 2013). Tyre retreaders were not affected by the waste tyre management plan
beyond REDISA promising to help raise awareness around the benefits of using retread tyres
(REDISA, 2012). One tyre retreader was interviewed, however, this participant was also a tyre
dealer and was counted as such.
There are over 3000 tyre dealerships registered under the REDISA plan and many more
in the country (DEA, 2018a). Tyre dealers are those who sell tyres, and in South Africa there is a
spectrum of informal to formal tyre dealers. Informal dealers would be those selling second-
hand/used tyres often by the roadside. Formal actors are comprised of those working under
national chains or franchises as well as more established independent actors. Under the Waste
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Tyre Regulations, tyre dealers are responsible for sorting tyres into 3 categories, those that could
be sold second hand, those that could be retreaded and waste tyres(RSA, 2009). They are
responsible for destroying any tyre classified as a waste tyre to prevent its future use (RSA,
2009). Thus, tyre dealers effectively determine if a tyre comes under the REDISA plan, or if it
gets sent into the informal reuse system.
Only two interviews were done with tyre dealers and both had a dual role in the industry,
one as a tyre retreader, the other as a tyre transporter. No contacts were made with tyre dealers in
the informal sector. While interviews were not done with tyre dealers they were contacted. I did
not seek interviews with either formal or informal tyre dealers because through my interactions
with them I got the impression that they were very minimally involved with waste tyres. Many
contacted were unaware of who collected their tyres or where the tyres were taken. Initially tyre
dealers were identified through internet searches however, I did not receive any responses to my
contacts made through those efforts and instead I visited tyre dealerships in person. Tyre dealers
were approached primarily as a means to contact tyre transporters.
Three members of REDISA management also participated in the interviews. When the
REIDSA plan was closed there were 178 people working in the REDISA head office. Those
interviewed were in senior management roles. These participants were recruited through other
participants and internet searches.
I was unable to recruit any participants from the Waste Bureau. The Waste Bureau took
over the management of the REDISA plan once REDISA was ordered liquidated and they are
currently managing the plan. I emailed and phoned several individuals working at the Waste
Bureau, but I did not reach anyone who was willing to participate in my research.
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Emails were also sent to 14 major waste management companies, these were identified
through internet searches and information provided by an NGO. Initially I was unsure if these
companies were currently or had previously been handling waste tyres. Through interaction with
them I learnt that they were not involved with waste tyres, although some handled other forms of
rubber waste not covered by the REDISA plan. Most did not participate because of their lack of
involvement with waste tyres. Of those contacted three companies participated in interviews,
however there were 4 participants. Of those interviewed one managed a private landfill site, one
was involved in rubber recycling efforts, one focused on waste-to-energy and one was a general
manager of the company.
One tyre stakeholder was interviewed. Tyre stakeholders have knowledge of waste tyre
management in South Africa, but do not have a active role in the system.
3.4 Data Collected
Semi-structured interviews were conducted with all participants. Because of the variety
of actors interviewed, semi-structured interviews were the most appropriate. This style of
interviewing allowed me the flexibility required to obtain information from participants, while
also having a clear direction about what information I was seeking. My interviews focused on the
following themes:
1. participants current and/or historical involvement in the waste tyre system, including
how they came to be working waste tyres, the work that they do, or their company
does and how this was affected by the REDISA plan
2. participants perception of the fairness REDISA plan and their experience working
under/with the REDISA plan and how the REDISA plan could be improved upon
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3. the supports and training that participants received to from REDISA in establishing
and maintaining their businesses
4. whether participants felt their role within the waste tyre system was sustainable and
the factors affecting its sustainability
Because of my incomplete knowledge of the waste tyre system, including the work done
by the various actors, the interviews also provided a means to understand each participant’s role
within the system. It was important to understand what they did with tyres and how that fit into
the overall tyre system. Through the interviews I sought to understand how and when people
became involved in working with waste tyres and if the decision to enter the sector was
influenced by the REDISA plan. I asked questions to understand how participants were affected
by the plan in terms of how tyres moved through the system and who they interacted with.
Furthermore, I asked questions with regards to whether participants thought that South
Africa needed a waste tyre management plan and the fairness of the REDISA plan specifically. I
also asked participants about their perception of what went wrong with the plan and what they
would have kept or changed about from the plan if they were authoring a new plan. Through
these questions I was trying to understand what people felt were the positive and negative
aspects of the plan and gain insight into participants experience working under the plan.
I also asked whether they received enough training and support from REIDSA in
establishing and running their businesses. I asked where they thought REDISA could have
offered more support. In their role of creating employment, and in the South African context
where many people lack necessary skills, I wanted to know how REDISA helped participants
overcome these challenges.
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I also tried to understand if the businesses and jobs that had been created were
sustainable. I asked participants if they felt their role within the waste tyre system was
sustainable, and how the sustainability of their role could be improved. I also sought to
understand if the REDISA plan was sustainable.
Attached as Appendix C is a copy of my interview guide. The interview guide evolved
slightly throughout the interview process as I tested it and then improved it. In the attached
document, questions that were added or modified have been included in italics. Due to the
diversity of participants, not all questions were asked to each participant. I also used interviews
to try and confirm what I had heard with other participants, this line of questioning has not been
recorded as it was tailored more specifically to each type of interview participant. Interviews
lasted between 15 minutes and 2.5hrs, with most lasting between 30 and 60 minutes.
Where possible, interviews took place at participants places of work, including 3
processing facilities, 3 waste tyre depots, a landfill and 4 tyre dealerships (some tyre transporters
had associations with tyre dealerships) and 3 offices. Conducting the interviews onsite provided
me with a chance to witness their operations which allowed for a greater understanding of the
work being done. I was able to see the day to day operations for processing, sorting and storing
tyres as well as collection and retreading. While this information will not be cited directly in my
research, it has contributed to my understanding of participants roles within the waste tyre
system. Other participants were met in public places including malls and restaurants.
At the conclusion of the interview, I asked participants if they were willing to be
contacted with any follow-up questions. This allowed me to seek clarification of any issues that
emerged during subsequent interviews or transcription. All interview participants indicated that I
could contact them with any additional questions, although when contacted I did not receive a
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reply from all of them. Where replied were received, this information has been used in my
research. I also confirmed with participants whether they would like to receive a summary of the
results of my research.
Of those interviewed, 26 were recorded in person and transcribed, 4 were recorded via
skype and transcribed and 3 were done in person without recording. For those done without
recording, detailed hand-written notes were taken throughout and then written-up with some
additional details from memory either the same day or next day after the interviews. Hand
written notes were also taken during recorded interviews. All recorded interviews were later
transcribed. I omitted some portions of the interviews from transcription when we were
discussing logistical things, such as the consent form, the purpose of my research and other
portions that I did not feel were relevant for my research. In some instances, I could not hear
what the participants said in the recording and indicated a gap in hearing with a (?) symbol in the
transcript. Interviews were transcribed in such a way that identifying elements were removed,
this included company names, place names and individual names. This was done to protect the
anonymity of participants. Additionally, all recordings and transcripts were saved using an
identifying number, and no participant information was included. All participants were given the
option of reviewing their transcripts or notes.
Other sources were also used to understand REDISA’s and the Waste Bureau’s
implementation of the plan. These included:
• The REDISA plan
• REDISA’s Annual Report 2015
• iSolveit’s 2017 auditing report assessing the implementation of the REDISA plan
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• Minutes from meetings of the Portfolio Committee of Environmental Affairs obtained
from the Parliamentary Monitoring Group
• The Department of Environmental Affairs, and the Waste Bureau presentations slides
about waste tyre management
• Court decisions and judgements between SATRP, RMI and the DEA and REDISA from
2012/2013, as well as between the DEA and REDISA in 2017
• Various news and media sources
3.5 Data Analysis
During my time in the field I used a constant comparative method and throughout my
interviews and transcription I tried to identify themes. I then tried to confirm these observed
themes through my questioning in further interviews. In some cases where themes emerged after
I had already completed an interview with participants, I followed-up after the interview to try
and confirm the new theme.
I have used coding in order to categorize comments from the participants along relevant
topics and themes. This was done to ensure there was adequate support for my identified themes,
as well and to determine if any other themes emerged. Coding was done using NVivo software
which enabled me to create, merge and remove themes as needed. This coding was done in two
phases. One round of coding was done while I was in the field and before all interviews were
completed, and a second round was done at the conclusion of my interviews. The initial coding
phase was used to ascertain what evidence I had to support my observed themes. I also used this
as an opportunity to refamiliarize myself with interviews done to date and to see if other trends
emerged that I had not noticed previously. While I did not use this coding directly for my
findings, it was a useful process in the constant comparative method.
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The second round of coding was done after all my interviews had been transcribed. I
went through each interview transcript and did a more focused round of coding based on what I
had determined to be important themes. I brought together both comments that supported and
challenged points to get a holistic understanding of the issues. After this round of coding, any
coded information was considered, and points and counter-points were selected to be included in
my results. Given that my sample size was relatively small, I was able to recall a good deal from
the interviews and in some cases I went back into the transcripts while writing to gather
additional information and quotes.
To draw conclusions from my study I used principals of political ecology and considered
how different actors within the system benefited or were challenged by the implementation of the
waste tyre management plan. I considered how the themes identified could shed light on the
power dynamics that existed within the system.
3.6 Limitations
A limitation of this research was that I did not come to fully understand how the second-
hand tyre system works in South Africa. As far as I understand, there are other transporters who
come to dealers and then pay a fee to take away tyres that are still reusable. These informal waste
tyre transporters then sell them to informal second-hand tyre dealers and perhaps retreaders. I
think in some cases second-hand tyre dealers also come directly to the dealership to purchase
waste tyres. Second-hand dealers are common throughout the poorer areas in South Africa and
account for a large number of tyres on the road (Phale, 2005). I understood from the micro-
collectors that they would then collect waste tyres from these second-hand tyre dealers and
therefore these tyres seem to be returned and processed through the REDISA plan. Tyre
transporters registered under the REDISA plan reported to me that it was not worthwhile to
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collect reusable tyres and that they were only supposed to transport scrap tyres, and I do not
think REDISA transporters are involved with this informal movement of tyres.
It would be interesting to research further how this second-hand tyre system was affected
by the REDISA plan. I heard from some transporters that there were individuals who had been
doing similar work prior to REDISA but did not become transporters with REDISA; however, in
some cases I was told that these individuals were still working with tyres. Unfortunately, I was
not able to interview these individuals and I do not know why they did not work under the
REDISA plan. It would have been interesting to understand why some workers in the informal
sector did not come be working under the plan. Understanding this system would also help to
understand the extent to which waste tyres are being captured by the REDISA plan.
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Chapter 4 – Results
In this Chapter I have presented the results of my research. In order to protect the
confidentially of participants, I have removed identifying information and I have referred to them
only by their role within the waste tyre system and a number corresponding to their interview. At
the end of this Chapter, I have summarized my finding about the waste tyre system in South
Africa through a lens of political ecology.
4.1 Waste Tyre Management in South Africa
As part of my interviews I tried to ascertain whether participants thought South Africa needed a
waste tyre management plan. The response was almost entirely affirmative. Although also in
support of a waste tyre management plan, two participants offered different perspectives on how
it should be structured. The first participant thought that rather than have a PRO manage the
system, it could be automated and managed through technology. This participant felt that another
benefit of this would be to decentralize the power within the system which would result in a
more fairly administered plan.
“So definitely going forward into the future, I think technology could play a [role] in that
area, and could actually run the whole plan autonomously… I think it could be done with
things like smart contracts and that. That kind of thing, maybe that’s a little bit forward
thinking, but there is no reason why it can’t, it already exists in different industries… But
I think the logistics, the collection, the payments. All that can be done with technology
moving forward. I don’t think we need a centralized party to control that kind of thing.” –
Processor 40
Another participant considered that the plan had benefitted some, such a processor receiving the
subsidy, over others, such as a pre-existing tyre shredder who relied on their product being
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considered a fuel for purchase which would become more difficult where REDISA supplies tyres
for free, or with a subsidy.
“So there are two points to this, and I think, and it depends which camp you are sitting in.
I think if you are sitting in the camp with the tyre processor, you would say, hell yes there
needs to be a plan, because hell yes, we need to get paid. And we need to get paid so
there can be more and more tyre processing plants, that we can purchase more and more
of the equipment.
On the other hand, the guys who are actually doing the shredding of the tyres…. He
wants, he thinks of tyres as being a fuel… So you need to be, this is a fuel, you need to be
paying me for a fuel. I can’t go and spend this money, and process tyres, and shred them,
and now bring them to you, and you tell me I must pay you more money to accept them.”
– Waste Management 37
Finally, one participant felt that the waste tyre management plan wasn’t required, and that
processors shouldn’t receive their raw material for free. However, they still felt that some
support was required for processors and it was unclear where that support should come from.
“I personally think… we don’t need this plan. If they in the beginning invested into the
processors. Because at the processors they need this stock. So, then I should have taken
it, like scrap metal, I should have taken the tyres there and they should pay me, the
processor, because that’s their raw material. … Directly to the processor because he pays
me because I gave him his product to work. There shouldn’t be extra taxes… Because
now the processors get their raw material for free and where does that happen?” – Tyre
Dealer/Transporter 33
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4.2 Benefits and Criticisms of the REDISA Plan
4.2.1 Good Plan/Bad Management
The REDISA plan itself was often praised as a good plan by participants, however many
felt that the plan was not implemented as written. A common sentiment that was expressed
through the interviews was that while it was a good plan, it had been poorly managed. The
criticisms of the management of the plan largely centered on the corruption and greed of
REDISA management. When describing the corruption, participants referred to allegations that
had been reported in the media. For many participants the corruption was one of or the only
problem that they identified with the REDISA plan as described by this quote:
“What I will say is, I think the REDISA plan, with some of its flaws, definitely was a
very good plan. I think the principal of it was good, in theory. The structure of it was
good. Where it seems to have fallen flat, in media, it seems to be on the governance side
of things, and not so much elsewhere” – Processor 26
All participants addressed the allegations of corruption and while many expressed surprise, there
was also a sense that given the amount of money in question, corruption should be expected in
South Africa.
“The concerns the informal tyre retailers had, were probably right. They were concerned
about top management, they said top management have sinister motives, and it turned out
that they were right. When it hit our newspapers, it became known that these guys
enriched themselves with cars and property and cash. It was terrible, you know, it was
absolutely terrible. So the rebates we had paid on buying new tyres had went into the
coffer, and was used to fund their personal lifestyles. It’s because of corruption, no
control, corruption. Which is unfortunately, turns out, a big issue, big issue in our country
right now.” – Waste Management 14
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“I think it was greed, bottom line, there was a lot of money involved to be honest.
Although they did a lot of things, but a lot of things maybe wasn’t done above board. So
that’s where things go wrong, ya. Where money is involved it’s always going to be a
problem.” – Transporter 25
Another criticism that was raised against the management of the plan was that those in
charge lacked the necessary expertise. This was attributed to those at the top levels of the plan as
described in the quote below, but many participants also referred to operational failures such as
depots that did not meet the Waste Tyre Regulations and illogical transportation of scrap tyres
over huge distances when there were closer depots from which they could be sourced.
“REDISA was not an operational company. It was an idea, a concept. So suddenly here is
a person, a few individuals with a concept, that a lot of others wanted to do, and they got
the right to do it, but they didn’t have the operational expertise. So, on supply chain they
didn’t have the knowledge. So, it took them 3-4 years that this thing is not going to work
well. They had to get rid of a lot of, let’s say the entrepreneurial people, and get
operational people in. So, the first few years was difficult, because they were not aligned
to running a business, and that was problematic. But after that they got some good people
in. And as they got the good people in, government kicked them out.” – Processor 12
4.2.2 Environmental
REDISA was praised by participants for improvements in cleaning the environment of
waste tyres in South Africa. Prior to the REDISA plan many tyres were illegally disposed of in
the environment which posed both health and fire risks (Park et al., 2018; Phale, 2005). The
quote below from a tyre transporter described how they had been illegally dumping any tyres
which they were unable to sell to retreaders or second-hand dealers. When the REDISA plan
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began, they got a transporter job and instead of dumping they were then able to deliver scrap
tyres to the depot. Many tyre transporters, who had also been illegally dumping acknowledged
that REDISA solved their issue of how to deal with scrap tyres and they were grateful for the
economic benefit of the fee for delivering those tyres to a REDISA depot.
“We was called jobbers. We would go around to the tyre dealers and pick up their scrap
tyres and sort it out. And then we would get some casing we could take down to the
retreading companies. Some there would be maybe tyres with a little bit of tread on them
that we sell the second-hand dealers, and that is where our income came about. And of
course, the tyres that we can’t use, we went to go and dump it somewhere in the fields.
We was the naughty guys that went to go dump the stuff because there was no place to
take it. The municipality dumps was too expensive to take it to and that. So, we went to
go dump it out in the bushes and all that. Until the REDISA plan came up, when the
REDISA plan came up, it was something good. I manage to get myself into a transporter
job over there.” – Transporter 19
The fee paid for delivery of tyres to the REDISA depots was attributed with the reduction of new
dumping, as described by this participant:
“I still think that the producer pays is essential, I think the rebates are essential. You
know if you really want to stop people, especially illegally dumping tyres, and illegal
dumping in South Africa is a problem. You know they go, why must I drive 30km away
to a landfill and pay 500 rand per ton to have my tyres disposed of when there is a piece
of open grass there… But you can say to someone now, hey, I will pay you 20 rand for
every tyre you bring me. They are like, ooo, you know, when can I bring my truck… So,
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just from that point of view, to keep people honest and on their toes to really clean up the
environment. I think those rebates are essential.” – Waste Management 37
Some participants did acknowledge that due to the continued incomplete collection of tyres there
is still illegal dumping happening and that tyres are still available outside of the formalized
system.
“But because of the fact that they don’t collect all the tyres yet. So, people sitting with the
tyres what must they do with these tyres? So, there is no problem getting tyres outside the
Waste Bureau. At the moment, until they start collecting everywhere. You know, they
just put the word out, you can come and dump on my property. From tomorrow morning
the trucks come and dump. At the moment, they do the dumping in illegal places, they
find an area in the veld, go and dump it… So there is a problem, until the Waste Bureau,
for collecting is in full operation, it’s going to stay a problem.” – Processor 34
The main criticism against the REDISA plan with regards to the environmental goals was that
the focus did not stay on the environment and other aspects of the plan, particularly job creation
became more important. This will be discussed further in the job creation section below.
4.2.3 Operations
In terms of operations, REDISA was praised for being effective at collecting tyres to the
depots. Many felt that the logistics required to coordinate a national system for the collection of
tyres was well established. Participants recognized the challenges and complexities of organizing
such a system on such a large scale and praised REDISA for creating an entirely new
infrastructure to collect waste tyres.
“I think if, apart from everything, if we just look at the plan, I think it did have good
intention and it did have, it had the right systems in place because I think also, for the
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Waste Bureau to be able to continue with us now, is because we, there was an already
established system with REDISA. I mean, I think if REDISA plan wasn’t such a good
plan, things would have fallen apart now. But they did put in the correct measures and
systems and the right type of reporting and adherence to regulation, and it’s supply chain,
so you know the transporters are coming, you as a depot, you store or you pre-process or
whatever that you do, you then have to take it off to a processor. So, they created a
supply chain and I think it made sense.” – Depot 41
However, there were a few who criticized REDISA in this regard because the network was not
complete as it did not reach to all areas. Some participants also identified large Off-the-Road
tyres used on mines and solid forklift tyres as not having been collected under the REDISA plan.
The incomplete collection is described by the following participants:
“And then they only rolled out a few depots in the big centers. But what now about all the
small towns, there is lot of tyres, nobody collected there.” – Processor 34
Many participants felt that while the collection was going well, REDISA had neglected the
processing side of the system. Several issues were identified in this regard including insufficient
processing and the exporting of tyres as a solution to this despite that not being part of the plan
“The collection was quite good, they were up to collecting, and the figures shows they
were hitting their targets of what the government says to pick-up. But they weren’t
recycling, there’s not enough recyclers.” – Tyre Dealer/Transporter 33
The operations of the waste tyre management plan broke down somewhat when the Waste
Bureau took over as the depots quickly became full. Many participants felt that this was because
REDISA had maintained movement of tyres through the depots by exporting. According to a
Waste Bureau presentation to the Portfolio Committee of Environmental Affairs, between
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December 2016 and July 2017 REDISA exported approximately 33% of the tyres counted as
having been processed under the plan (12,473 tones exported of 37,816 tones processed, on an
annualized basis) (DEA, 2018c). The Waste Bureau did not continue exporting and they had
trouble moving tyres out of depot because there were not enough existing processors.
“I think where they might have not done so well is with regards to the processing
because there, obviously we all know, there is still a backlog, there is still a big difference
between supply and demand. So, I think if maybe they weren’t exporting some of the
tyres, because from what I hear they were exporting some of the tyres, I think if they
weren’t they would be experiencing quite a problem. Because we don’t have enough
processors in the country to offload all the tyres that we have.” – Depot 41
Participants were divided on whether exporting should continue. Some who felt exporting should
cease recognized it as a loss of a resource for economic development in South Africa, and a few
saw it as dumping waste on other countries. However, some felt that exporting should continue,
at least until there were enough processors established to maintain the movement of tyres
through the system, as is explained by this participant:
“REDISA exported. What is South Africa going to do with the tyre? Why can’t they
export it? ‘No we must create work for the people.’ You can say that in 10 years time…
But then, you build up processors and stuff, and make work for people who can process
the tyres.” – Transporter 19
While most participants blamed the backlog of tyres on the lack of exports, one felt that the
Waste Bureau lacked the expertise required to manage the system effectively as explained below.
Similarly, other participants reflected on the loss of knowledge that occurred when the Waste
Bureau took over as they did not retain any of the staff at the REDISA head office.
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“Unfortunately, yes there is the problem by the depot, it’s not that you can’t access it, it
is it’s full… when REDISA was there, there wasn’t problems like that because they had
people looking at things like that. Yard coordinators, depot managers, depot coordinators.
They had all that. So before the problem would arise, they were there, and REDISA
would sort it out. There would always be, there were always tyres on the move. They
spend a lot of money moving the tyres around to the depots, and to other holding depots,
and to the processors and that.
Remember the government, the Waste Bureau took it over, in November now. The
people that was running it had no knowledge of this whole system. REDISA, the Waste
Bureau thought they took this whole thing, it would be easy just walk into the building…
shift it around and it will work. It didn’t work out like that, because they didn’t have the
manpower, they didn’t have the resource to move the stuff around. So what REDISA
builded up in 3 years, they clogged it up in one month. They clogged it up in one month.”
– Transporter 19
As discussed in this section, most participants felt that the REDISA plan, as it was
written, was a good plan. Participants saw a benefit of the rebate offered for tyres returned to the
depots as waste tyres were removed from the environment and it minimized new dumping.
Similarly, participants praised the operations of the REDISA plan in terms of the collection of
tyres on a national scale, although some noted that this collection remained incomplete.
Alongside these benefits, the REDISA plan was criticized for poor management both in terms of
corruption and a lack of expertise. These comments highlight that while the REDISA plan was
considered to have been well written, the implementation was not considered to have been as
well achieved.
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The most common criticism of the REDISA plan was the lack of development of
processing capacity. REDISA was understood to have maintained a flow of tyres through the
system by exporting a large portion of the tyres collected and this has negative effects in terms of
future economic growth as the potential benefits from those tyres are lost from South Africa.
Especially where the plan was so focused on developing employment in South Africa this
exporting of tyres is problematic as tyres are the resource for growth. Some of the identified
challenges that slowed the development of new processors were the stringent legislative
requirements, as well as the poor quality of waste tyres in South Africa which affected outputs.
These, along with the supply of tyres and subsidies for processors will be discussed further in the
supports for processors section below.
4.3 Role of Government
Some of the benefits which were attributed to REDISA were benefits that would have
been derived from any integrated industry waste tyre management plan. Some participants
recognized this and acknowledged that is was the government who had called for the plan and
was therefore ultimately responsible for the benefits.
“But I must say it in context, the plan has always been, it was something that was
evolving through government. It wasn’t because of REDISA, it was our government
formalizing the tyres plan. That REDISA operated it, they were the only, they were the
successful bidders.” – Processor 12
At the same time as the government was praised for bringing about the IIWTMP, others saw that
the government had a role in the failures of REDISA, particularly when it came to the oversight
of the implementation of the plan. Most participants discussed a lack of oversight, while some
participants directly acknowledged that the government had a role to play:
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“… because I think, [the government] didn’t hold REDISA accountable enough, like,
they weren’t, I think they gave REDISA a blank cheque and they just said, ride with it,
implement the plan, see what you can do, give us the numbers. And then everything is
fine, you know. I think they probably should have been more involved… So I think they
probably should have established a body like the Waste Bureau already to work with
REDISA from the onset, so that they can monitor and evaluate them correctly. And truly
hold them accountable.” – Depot 41
A lack of oversight of the implementation of the REDISA plan was a common criticism
throughout the interviews. Many felt that more scrutiny into how the money was spent was
required especially given it was mandatory for producers and importers to pay the levy to
REDISA. Similar to the comments made about greed and corruption, many felt that the large
amount of money that was ultimately paid to REDISA required better oversight.
“And the management just wasn’t sophisticated enough to run this properly. They really
needed more like financial experience. The proper enterprise development experience.
Absolute independence of directors, and the conflicts of interest were huge and were
unacceptable actually. So these things require to be managed almost like asset mangers
are managed. You know like, under very stringent, kind of … transparent, and
professional, some sort of codes, you know.” – Stakeholder 04
Not only did the actors within the REDISA plan say that more oversight was required, but also
participants from REDISA’s management. REDISA’s management acknowledged that they had
self-imposed governance, but still felt that there should be more oversight of industry waste
management plans going forward.
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One change that was made during the operation of the REDISA plan was that the levy
would now be collected through SARS and be disbursed through the National Treasury. Many
participants saw this as a positive change that increased the oversight of how money was being
spent, as is described by the quote below. However, there were others that worried about the
funds being absorbed into the governments general accounts and not being allocated for waste
tyre management, as this had been done previously with the plastic bag levy (Nahman, 2010;
Godfrey & Nahman, 2009).
“… where the changes come in, the fact that the money first goes to Treasury, that’s
probably the better solution. As we have it currently, because now the money goes to
Treasury and Treasury pays out to the Waste Bureau to do the management of the work.
That is probably one of the things that you definitely will have to change. Because the
amount of money REDISA sat with, to a certain extent you would probably understand
why they made plans to, I don’t know how to put it exactly, but to channel some of the
money to unsavory, or not to the correct places… Even in the REDISA plan they kept on
talking about oversight and audits and this, that and the following, to ensure that
corruption and all of this doesn’t take place. But somehow you need to enforce this bit to
make sure that they money doesn’t disappear into somebody’s pockets somewhere and
it’s actually utilized for the correct thing.” – Processor 31
Alternatively, there were some participants who felt that the government did not have a
role to play in the failure of REDISA. These participants felt that the issues with REDISA were
theirs alone. One participant explained that they felt the DEA had every reason to support the
successful implementation of the plan, and therefore was unlikely to have done anything to
hinder its success.
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Some participants also referred to a tension that developed between the DEA and
REDISA management. This is also referenced in the minutes of the Portfolio Committee on
Environmental Affairs where individuals from the DEA describe REDISA’s refusal to provide
access to information and documents requested to assess the implementation of the plan, as well
as court cases brought by REDISA over what powers the Minister had over the REDISA plan
and the waste tyre levy (PCEA, 2017). Participants felt that this breakdown in the relationship
between the DEA and REDISA contributed to the eventual failure of REDISA. One participant
explained that where the REDISA plan was doing something innovative in South Africa, there
needed to be a strong relationship between the two parties to navigate implementation of the
plan.
Issues also arose around REDISA or later the Waste Bureau being both a regulator and a
player in the industry. A few participants recognized that there needed to be separation between
the two roles to ensure that the implementation of the plan was regulated fairly.
“Because I think the main, the main problem has been the Waste Bureau and the
Department [of Environmental Affairs]. You can’t be referee and player at the same time.
You see. So, they are also looking at getting another service provider, who will operate
like REDISA, and, so that at they can point a finger then say, you are not doing certain
things the proper way. Which, which will help a lot.” – Depot 28
4.3.1 Waste Bureau’s Management of the REDISA Plan
Following the court order to liquidate REDISA, the Waste Bureau assumed management of the
REDISA plan and this allowed participants to compare the management under REDISA to that
of the Waste Bureau. One criticism that was raised against the management of the plan by the
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Waste Bureau was that it was slow and bureaucratic, whereas REDISA had been quicker to make
decisions.
“It’s difficult to work with the government, you need to tender for stuff, so it takes a
while to get into the system. You know. Where REDISA, they was faster at everything,
because they were the main people, so they could decide, and go and do that, don’t do
that. That’s the difference… [The government is] slower, they are more stricter, a lot of
paperwork, so that is the difference.” – Transporter 25
Participants also felt that REDISA had been more accessible in terms of listening to their
feedback about the waste tyre plan and responding to any questions and concerns that they had.
Some participants complained that they were not able to get responses from the Waste Bureau
when they were seeking guidance or clarification.
“If there is one think I can account for [REDISA] on, it’s the support they did provide,
there was a lot of support. And I think also they have allocated, you know, dedicated
people that we could speak to directly, so I think that also made it easier, to get things
done.” – Depot 41
“And it was difficult for us to work with [the Waste Bureau], because you couldn’t get a
hold of them. Even until now, it’s very hard to get a hold of them. You know, to tell
them, this is the story, what must we do. It’s hard. … Ya [with REDISA], we could just
pick up the phone, we could go to the office, you pop them an email. And then we would
get a response ASAP. With them it’s a little bit different, with the Waste Bureau, maybe
take them 3 weeks to get back to you, and we have to figure it out ourselves.” –
Transporter 25
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The role of the government in the REDISA plan shifted over the course of the plan’s
development, implementation and then subsequent liquidation. The government, through
legislation created the framework for an IIWTMP and subsequently called for proposals for such
a plan. Recognizing this some participants associated the benefits of the REDISA plan with the
government. However, when the corruption of REDISA was exposed, the government was also
criticized for a lack of oversight of the implementation of the plan and was seen to have failed in
its regulatory role. The need for oversight highlights the importance of establishing separation
between regulators and actors in the industry, as REDISA can be seen to have failed in
regulating itself. This failure led to the liquidation of REDISA and subsequently to the Waste
Bureau’s management of the REDISA plan. This allowed participants to compare management
under government to management by REDISA, with participants reporting that they were met
with a slow and bureaucratic process that was more difficult to work with than REDISA had
been. Other critiques of the Waste Bureau are discussed throughout the results section, including
job losses under their operation of the plan and poor operational capacity.
4.4 Job Creation
Job creation was a priority of the REDISA plan. As has already been discussed, the
legislation required that job creation be considered when creating a waste tyre management plan
(RSA, 2009). The REDISA plan set out to create 10,000 jobs and this projection was broken
down as seen in Table 4 below. The information in the first 3 columns of this table were taken
from the REIDSA plan, including the wording used. “Projected Number of Opportunities,” refers
to opportunities for the creation of a business. I have added the row for micro-collectors which
were not included in the projected of job creation in the REDISA plan. The fourth column was
taken from a undated report which was provided to me by a research participant from REDISA’s
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management and refers to the jobs created under the REDISA plan by February 2016. In the fifth
column I have included the numbers of businesses and jobs existing in March 2018 as per a
Waste Bureau presentation.
Description1 Projected
Number of
Opportunities1
Projected
Jobs to be
Created1
Jobs Created as
reported by
REDISA for
Feb 20162
Existing
Jobs/Opportunities
in 20183
150 depots 150 1800 214 21 depots
Shredding
businesses
3 30 - -
Potential of 200
different recycling
operations
50 1000 191 9 active of 12
operations
Small transporters 4000 7000 507 74 businesses
REDISA head
office
100 127 -
Micro-collectors* - - 1972 206
Total: 9,930 3,011
Table 4: Jobs and opportunities projected to be created by REDISA versus those reported
by REDISA in February 2016 and those reported by the Waste Bureau in March 2018. 1: REDISA, 2012 pg. 28; *Micro-collectors not included in REDISA, 2012.;
2: REDISA, n.d.;
3: DEA, 2018a, slides 6,7,9,11
The actual number of jobs created is very difficult to ascertain due to the various ways in
which they have been projected and reported. REDISA was criticized for counting micro-
collectors as being jobs created upon them registering with REDISA regardless of whether they
ever collected any tyres (iSolveit, 2017). Additionally, in the REDISA plan, it was noted that the
job creation projections “exclude any estimate of numbers of informal collectors” (REDISA,
2012: 28). However, in a document provided by a participant from REDISA’s management, it
was stated with regards to micro-collectors that “a job is a contractual entitlement to be paid for
work performed, and so they are reported”. Thus, REDISA felt that since there was potential for
those collectors to earn, they have created a job. This raises another critique of REDISA’s job
reporting around what definition of a job was being used (iSolveit, 2017). To this a participant
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from REDISA management explained that they create businesses and not jobs and that they
relied on reported numbers of jobs from the business opportunities they created. Despite any
challenges in determining the absolute numbers, REDISA fell far short of reaching the job
creation targets which were set in the REDISA plan.
REDISA said that the projected jobs were calculated based on tonnages of tyres they
expected to arise every year (REDISA, n.d.). They initially predicted that there would be 48.5
jobs per 1000 tonnes/year, however, in 2016 when they ceased operations they reported to have
created 29.2 jobs per 1000 tonnes/year (REDISA, n.d.).
The REDISA plan did not create nearly as many jobs as was intended, and many
participants felt this was due to an initial overestimation. Some participants discussed the
pressure to create jobs in the South African context, both in terms of projects seeking support
from government generally and more specifically about the REDISA plan as seen below.
“Because they would much rather have something that gives us 200 jobs. Where 190 of it
is low skilled labour that can employ local communities. And it can be a worser
technology, it can cost more. It can be all that. But no there’s no labour portion. ‘Where
are you uplifting the community. Where are you doing this? Where are you doing that?’
There’s a lot of portions that just aren’t thought about overseas, where they try and sell
turnkey technologies. Technology is fantastic, but it doesn’t work in the South African
sector.” – Waste Management 06
“Well [they overstated the job creation] because its, its, its all the political reasons, you
know. I mean in order to get something, remember, at the time that REDISA pushed it
through the government, it was the first time ever that this was happening... You know,
so there was an element of overestimation and there was also a political element of we
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can get this through parliament if we promise to put 10,000 people to work. And that was
the important thing at the time.” – Stakeholder 04
Some felt that the focus of the plan, and the reporting that was required of participants reflected
an overemphasis on job creation. Participants described monthly reporting which required them
to detail all their employee’s information to REDISA, including ID numbers and any hiring or
terminations. Some also identified that the focus on job reporting overtook to environmental
importance of the plan.
“I think at the end… the focus just stayed on employment, employment. And the most
important things, the report at the month end was not about how many tyres we
processed. It was about, we want the ID, identification of each individual working. I had
to sign it off as head of the [processor]. I thought, what’s this. But they just had to prove
to government.” – Processor 12
“What happened with REDISA as well, because the… the pressure on the jobs was so
high, right from the beginning, from 2012. You know, because now suddenly they made
these promises to the government. The jobs because the main, like, driving force of this.
And everybody was forgetting that, like, hello we actually exist here because of the
waste. It is the environmental impact, that is a priority, that should be the priority, not the
jobs. But because the government now had this amazing number in their heads, and they
wanted to know how it’s going. There were not asking well, hey, how many, well they
were asking that too, but alongside, almost on the same level of the first question of how
much waste have you recycled or taken out of the environment, they were asking well,
how many jobs have you created? So, it became easier to create the jobs than actually,
take the tyres out of the environment.” – Stakeholder 04
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It is also interesting to point out that participants from REDISA management stated that the
REDISA plan could have been implemented in a way that created far fewer jobs than the existing
plan did. This echoes the statement in the REDISA plan that “although somewhat secondary to
the goals of job creation SMME support and BBBEE, waste tyre management is a necessity that
needs to be addressed effectively and efficiently” (REDISA, 2012:7). One example given by
participants of how this could be done was through hiring a logistics company to manage the
transportation of waste tyres, rather then the multitude of tyre transporters who were hired. This
would have reduced REDISA need to manage the plan and likely increased the effectiveness and
efficiency of the implementation of the plan.
4.4.1 Waste Bureau
The Waste Bureau was criticized for the job losses it caused when it began managing the
plan as can be seen by the quotes below. More importantly, in a presentation done with regards
to management of the plan, the Waste Bureau described one of their successes as being that they
had “Outperformed Redisa in both collections and recycling but with far less resources: Less
financial resources & less staff complement - 34 (6 when WB took over in Oct) Vs Redisa 178”
(DEA, 2018c). Jobs were reportedly lost at REDISA head office, and at the some of the depots,
as described below:
“Because, I know about the one office … the head office, we are not talking about the
CEOs and the directors and all that. You are talking about the ordinary middle manager,
down to the call center girl or guy who was sitting there. Over a hundred of them was
fired. So where does that job creation come in?” – Transporter 19
“[The Waste Bureau], when they gave me the new contract they let 7 people go. They
are about job creation, what is that shit? Aren’t you supposed to, isn’t that a problem in
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this country that people don’t have work? … So why did you ask me for salaries and
budget and stuff and then you still cut these things. That to me I could never understand
it. I still can’t understand it.” – Depot 20
4.4.2 Recruitment of Actors Under the REDISA Plan
Interview participants were also asked about their recruitment into the waste tyre system
as well as their role in the recruitment of others. In the REDISA plan, people were invited to visit
a website and enter their details as a means of applying for any of the roles within the waste tyre
system (REDISA, 2012). All applicant’s data was then compiled into a database. Of the
participants interviewed, only two reported being recruited through this database as seen below.
“So, we did apply, but it was a very short submission… It was, you just had to fill in your
company details, and what you would like to do. So, either be it a depot, or a transporter,
or other things, I think micro, no micro-collectors weren’t there yet. Yes, it was depot,
transport and processor. So, we just chose the depots, and then after the call is when they
wanted the final details of, who we really are and stuff like that.” – Depot 41
“You know very strangely, I was working for another other guy… And the manager… he
told me, listen, there was a guy here about a month ago, telling him of this whole tyre
industry coming into the fore. Listen I am going to bring you the papers and you can fill
them in and we can just fax it off to them. … And I think maybe a year and half later I
got a call, asking if I am this guy, I said ya, I’m this guy. So, they wanted to meet me, and
I said ya, that be cool. … part of filling in the application ask you what kind of vehicle
you have. By that time I didn’t have a vehicle to be honest. I just said ya, I got a 4-ton
truck, this, that and the other. And then they called me, you have a 4-ton truck, and then I
said ya I do. I didn’t have. And that’s how I started.” – Transporter 25
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Overall the recruitment process seems to have been fairly arbitrary. This can be seen as a benefit
where a formal application and strict criteria and requirements would likely exclude actors from
the informal sector and PDIs (REDISA, 2012). However, there was an adjudication process
described in the REDISA plan, which no participant reported going through (REDISA, 2012).
Most of the interview participants were recruited through knowing someone who was connected
to the REDISA plan, or who was already working with REDISA. In one case a participant
reported becoming manager of a depot through a relationship with the CEO of REDISA. The
following are statements which reflect this type of recruitment:
“The person who was running, who had the contract with REDISA. His accountant told
me, here’s a job for you, come and do this. And so I thought, let’s just try it.” – Depot 20
“Eventually a friend of mine was in the business with REDISA as from day one. He
asked me, what is the possibility that you can come and join us. I said okay not a
problem, I will come and join you. So, I joined, how can I say, the transporter in
REDISA.” – Transporter 21
At the micro-collector and transporter level many participants were contacted directly
and offered a role within the system. A participant from REDISA management described that
when they were seeking transporters in a new area, their first step was to go to tyre dealers and
ask about who was already collecting their tyres. Contact was then made with these existing
transporters to invite them to register under the plan. At the micro-collector level, one participant
was identified through an existing community databased of local cooperatives, and another
through association with an NGO. One participant described a larger effort to recruit micro-
collectors, which is included below. In this instance, a meeting was announced over the radio and
then all community members who attended were invited to register as micro-collectors under the
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plan. This description of recruitment reflects the ease with which individuals could register as
micro-collectors even without any demonstrated commitment to collect waste tyres. This helps to
understand how so many micro-collectors were registered and included in job creation numbers,
despite many never having collected any tyres.
“Anybody who came. Because [it was announced on the radio], that there is such a
meeting, those interested people can come. The hall was full of people, and [REDISA]
gave that presentation. And some of the people, community members were happy about
the presentation. Then they take photos, they get cards and everything. Become tyre
collectors, although some didn’t collect tyre, but they have cards.” – Micro-collector 38
An aspect related to job creation that was positive is that participants throughout the waste tyre
system were mindful of the goal to promote job creation. They recognized that their working
under the plan also allowed them to create further opportunities for employment for others.
Several participants at the transporter and micro-collector referred to leaving work for others to
spread the benefits of the waste tyre industry to more individuals. This is seen in the following
quote where the participant described that they could take on three roles within the system, but
instead, they explain that the roles should be separated and left for others.
“So in terms of job creation, there is a lot, a lot, a lot of jobs in the tyre industry. Others
are collectors, others are making furnitures, others are the truck delivery. So that you
collect, you put in the container, the trucks will come and collect. Like there is the micro,
I am the micro-collector, there is the micro depots, there is the micro-transporter. Even if
you want you can do even, three per one. As the tyre collector, as the tyre depot, as the
tyre transporter … You can do all the roles as you are one. Because for job creation, so
that you will try to separate for others.” – Micro-collector 23
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At the depot level, some participants reported that there was guidance as to who should be hired
and that the focus was on recruiting people who were currently unemployed and previously
disadvantaged.
“I think the one thing they stressed is that, we should try hire people that don’t have a job.
So people that aren’t currently employed. So that we really try and make the impact we
were trying to make. So that was the one thing that they said. Try and get people who
aren’t working, so that, I guess you are starting new with people, or something like that.”
– Depot 41
4.4.3 Political Appointments Under the REDISA Plan
Some participants also referred to others who had been appointed for political reasons. These
allegations were directly primarily at those who were going through REDISA’s incubation
program and who had been supplied with equipment and/or funds to establish their business.
Both recruiting people from politically linked organization and the incubation process were
however part of the REDISA plan. In the REDISA plan it is stated that in order to create
opportunities for PDIs, “the role of Veterans Organisations, women’s and youth leagues in
identifying candidates from their own ranks and that of other civic groupings is crucial”
(REDISA: 2012: 27). REDISA explained this recruitment as well as the incubation process
through its response to the airing of these allegations in the Carte Blanche episode:
“To clarify, REDISA is procuring equipment as required in terms of section 15 of the
plan. REDISA is not buying equipment for any individual person, and the equipment
being purchased is necessary to create capability in the country to deal with waste tyres.
This is in line with REDISA’s mandate to develop a viable and sustainable recycling
industry.
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Since REDISA cannot own any of these businesses in the long term but has a vested
interest in catalyzing a new industry, a business incubation programme has been
developed to deliver to this mandate.
The incubation programme:
a. looks to prove the business viability of the machinery within the recycling
industry
b. looks to create and develop businesspeople/ entrepreneurs within the new
industry
During the proof of concept phase, REDISA owns the business to establish
profitability/viability without exposing the entrepreneur to risk. Where the business
proves to be viable, the ownership of these businesses is passed to candidates who meet
with specific performance indicators in terms of compliance, operational management,
financial management, product and market development.” (REDISA, 2015b).
Despite it being provisioned in the plan some felt that these appointments were unfair. One
participant also raised concerns that the equipment purchased through the incubation program
were used to directly competed with other processors who had not received the same benefits.
“Look REDISA when they came in, they were just supposed to be like regulators into the
market, and just trying to mop up the tyres, and help processors do their own thing. But at
the end of the day they ended up being players in the market. You see. So, from that point
of view, whereby now they are receiving resources from the government, through the
waste tyre tax. Then they come into the market they buy these big machineries and all
that and all that. Then they start doing processing on their own. Instead of actually going
there and supporting the existing players.” – Processor 16
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However, another participant recognized that to create a SMME this sort of funding up front is
likely required, and they thought that it was justified, as quoted below.
“But to answer your question, yes they did obviously provide some capital up front in
some instances. I’ve not got confirmed events of that, but I know there were places where
they said, okay, you are going to process this many tyres, we will bank 6 months of your
processing that, and pay you that up front, and then not pay you out for. Which I think is
a fair way of working, and you need to do it case by case, unfortunately. And I think they
maybe got a lot of slack for that, I’m not sure, or a lot of flack for that. I think maybe in
an informal market where you are trying to formalize it, it sort of happens where you take
it case by case, and you decide, you know, this is going to work for this guy. You need to
make a judgement call, unfortunately.” – Processor 26
When considering job creation under the REDISA plan I have sought to understand both
how and for whom jobs were created. Jobs were created at all levels of the waste tyres system by
creating an infrastructure around the collection and distribution of waste tyres. However, the
total number of jobs was far less than projected and this may be due to an initial overestimation.
This overestimation can be understood to have been driven by a political need in South Africa to
reduce unemployment and to create opportunities for those who were previously disadvantaged
especially within the context of addressing the injustices of apartheid.
In considering for whom jobs were created under the plan, the recruitment of new
entrants into the waste tyre system was arbitrary and largely driven by people having connections
to those already working under the REDISA plan. REDISA was criticized for the political nature
of some appointments, particularly those in the incubation program, even though this has been
provisioned under the REDISA plan. There do seem to have been efforts to recruit those who
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were previously disadvantaged under the REDISA plan, however, the lack of a formal system for
recruitment raises questions of fairness and equal opportunity.
4.5 Integration of Actors from the Existing Informal Sector
The REDISA plan acknowledge a need to integrate actors from the exiting informal
sector into the new system being implemented under the plan. At the inception of the plan,
transporters were the focus for integrating actors from the informal sector. However, later when
micro-collectors became part of the plan, there were some efforts to integrate existing waste
collectors as will be described below. Existing processors in the informal sector were not
considered in the plan and do not seem integrated into the system.
4.5.1. Transporters
With respect the tyre transporters the REDISA plan stated “specifically, the REDISA
plan will avoid criminalising current waste tyre collectors, who are presently operating outside
the law, by assisting them to enter the industry as respected participants. This will be achieved by
REDISA’s aim of granting loans, training and mentorships to entrepreneurs in order to develop
them as independent businessmen.” (REDISA, 2012: 26). Of the six transporters interviewed, all
but one was working with waste tyres prior to the REDISA plan. Under the REDISA plan were
obligated to register as businesses for tax purposes which had not previously been required of
them. Even if they had previously been working as a tyre transporter when they registered with
REDISA tyre transporters were counted towards the jobs and businesses created. In addition to
their own employment, all transporters who had previously been working with waste tyres
reported that they were able to expand their business through hiring more employees and buying
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more trucks, bakkies4 or trailers. The new entrant reported that they had also hired 2 employees
and thus created work.
As described above, REDISA promised that it would support transporters through
granting loans, training and mentorships to entrepreneurs. Training and support can be very
important for integrating people who are working in an informal system. Transporters had both
positive and negative things to say about the supports and training that they were offered. One
reported that without REDISA they would not have had a business that was tax compliant.
“I was one of the guys, what REDISA did for me was knowing that, my background
comes from you know, on the certain time we didn’t want to go to school, we didn’t
finish school, again, so we don’t really got education. … But when REDISA came,
REDISA helped me, personally me, there was a few other people as well, but REDISA
helped me to register a business that was compliant with the government. And it is what,
one of the main things that REDISA did for me. They took me out of an informal entity,
and into a business plan entity… I had to get everything, but they guided me into that
direction. Forcing me to have a registered business. ‘You need to have your tax
compliance, you need to have a certificate for waste tyre transport, you have to have this.’
And through the 3 or 4 year that REDISA was there, they guided me into getting all that.
… I acknowledge that without REDISA, I wouldn’t have a registered business that is
compliant with government.” – Transporter 19
Another indicated that the training was primarily administrative in nature:
“There was no training at the start, I think that, there wasn’t a lot of training. Most of the
training that was given to us was more admin side, in terms of how invoices should be
4 A bakkie is what would be referred to as a pick-up truck in North America. It is a small truck with an open body and low sides.
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put forward. … They also had, they had also given us, like… like grievances from the
tyre dealer. So if you have grievances fill out this form and send it in. That’s the kind of
training…” – Transporter 25
In terms of loans and mentorship, none of the participants reported receiving any loans or
mentorship opportunities through REDISA. Alternatively, the Waste Bureau did provide
transporters with funding as a start-up fee, which could be used to manage transporters monthly
budget:
“[The Waste Bureau] gave us a fee, a start-up fee. Which REDISA didn’t, even though
we was running 3 years with REDISA. They gave us a start-up fee, and that is actually
what helps me. They gave each one the same amount and that. And I used mine, for my
advance payment for the diesel and things like that.” – Transporter 19
One transporter also described having made a request for funding for a new truck, but that his
request was denied:
“There was, and I read in the REDISA document, that if you were a transporter inside
REDISA and you required a bigger vehicle, REDISA would then be able to assist you to
obtain vehicles. But unfortunately, like I said, greedy people must be outside, but
unfortunately in the REDISA plan the greedy people was pushing you away from that
structure, to uplift you in terms of vehicles and job creation. Because you as a transporter
the minute you create 10 vehicles, you create 10 jobs. … And I put a, what do you call it,
a request on the table and it was bluntly denied. ‘We cannot do it.’ What reason? I don’t
know. …They just said no.” – Transporter 21
Some transporters also spoke of others who had previously been working with waste
tyres, but who did not work under the REDISA plan. Most participants were unsure as to why
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others had not come to work under REDISA, but they offered some ideas, as described below. I
was not able to contact any of those who did not work under the REDISA plan and therefore do
not have first hand information about why they did not participate.
“I think there was, there was, too many rules and stuff. They don’t want to get into this
because it’s too many, you must have this, you must have this. … It was, by the
beginning … We made a lot of mistakes, that why we didn’t get paid. And people were
just moaning, and the guys who work for you moan. … ‘Well you see what happened,
well your paperwork wasn’t right’, or this wasn’t right, or this wasn’t right. But there
were sometimes, they were supposed to pay you, and then they don’t pay you, then they
tell you your paperwork wasn’t right, instead of telling you before. … So other guys were
staying there, I don’t want to be in this.” – Transporter 15
“I think, I know one guy, I don’t know where is he in the world, I know he stopped
because of financial reasons. … Because, you know, when we kick-off, neh, we basically
kick over with very small amounts. The rate was very low.” – Transporter 21
Under the Waste Tyre Regulation, tyre dealerships are responsible for sorting waste tyres
from tyres that could be resold as second-hand tyres or to a tyre retreader. Any tyre which the
tyre dealer deems to be a waste tyre is to be destroyed by the dealership so that it can not be
reused and given to a REDISA transporter. Tyres that are classed as re-sellable as second-hand
or appropriate for retreading do not come under the REDISA system, but instead go through an
informal tyre system which I did not research. Although I was unable to speak to anyone
directly, some participants described the work done by tyre transporters who are collecting the
re-sellable tyres. This work is similar to that done by tyre transporters who were working with
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tyres prior to registering under the REDISA plan except that they would also have collected
waste tyres and in most cases dumped those illegally.
“Now, basically what it is now, the whole industry changed. The dealers, where the tyres
is, they will sort it themselves now. You will get guys from Zimbabwe and that, that will
come here and buy the second-hand tyres from them, so they will take the second-hand
tyres out. Whatever can be retreaded for them, they send to the retreaders and that. And
the balance, that is what actually for now what belongs to the government. How they call
it, you know, scrap tyres. They must have a registered scrap tyre transporter to transport
that tyres.” – Transporter 19
“The dealers they still sell the second hands, to the others. The scrap they give to us…
We don’t sort it when we are there. They already sort it before we come. We know that
corner is our corner. That corner, is not even, we mustn’t touch that corner.” –
Transporter 15
4.5.2 Micro-collectors
Micro-collectors were not initially considered in the REDISA plan, however they ended
up being the area with the largest reported job growth. REDISA planned to continue to bring on
more micro-collectors as can be understood by this statement “the increasing emphasis on micro-
collectors, which will increase the effectiveness of servicing the remoter and/or less formal areas,
is expected to result in a higher ratio of jobs to tonnage to be collected, starting in the current
year 2016.” (REDISA, n.d.). Micro-collectors had to be registered with REDISA in order to be
paid for delivering tyres. With registration they were provided with a REDISA card and were
provided with an eWallet to which they were paid (REDISA, n.d.). Micro-depots and depots
would not accept tyres from those who were not registered. This created a barrier to entry for
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waste collectors in the informal sector and likely limited their ability to participate as some
would not have known where to register or where to get information, as is described by one
participant:
“The container that I saw it’s where I am staying … There as a big red container there.
But the tyres are coming slow. So, I don’t even know the owner of that container. Just
saw a van coming there and offload, then it goes… Nobody is operating that container.
Because always when you got there the door its closed, you can’t even ask questions.” –
Micro-collector 30
A complaint voiced by all the micro-collectors interviewed was that they were paid the same for
any tyre collected. Participants did not understand how they could be expected to carry a
motorcycle tyre or a truck tyre for the same fee and this was also a deterrent to participation.
The same participant described how when REDISA came to try and recruit them and other waste
pickers, they did not adequately present the plan. According to the participant, they were handed
pamphlets outlining the price that would be paid for tyre and nothing further. The participant felt
that they should have held a meeting to explain why they should change their practices and also
to allow potential participants to understand the process, ask questions and voice their concern.
“I can’t, waste pickers don’t like that, I want somebody to talk to face to face and
understand what is really going on here… Not just a piece of paper with prices. Uh, uh
we don’t like that. Unless it’s something we are working with daily. Because like, this
REDISA thing, wasn’t so much into us, because like, we used to burn the tyres, now you
come with another strategy, you say don’t burn the tyres because we are doing oil with
them and this and this, and when you burn them the resources and everything. I still need
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to study for that. Remember I am a waste picker, you need to teach me. You know, put
me on the table and say no, you don’t want to do this way.” – Micro-collector 30
4.5.3 Processors in the Informal Sector
There were also some actors in the informal sector operating as tyre processors, being
those who did not possess the proper licenses. These actors were not brought into the REDISA
plan. Participants identified that informal processors were mostly involved in pyrolysis. Many
participants were aware of these operations, and some felt that they are creating a negative
impression of pyrolysis as they understood these informal processes to be polluting. Some
participants also spoke about fires at informal processors, as well as one death which had
occurred, which speak to the risks associated with tyre processing.
One processor in the informal sector was interviewed, they had not made any attempt to
work under the REDISA plan and they are currently in the process of addressing the legislative
requirements so that they can be processor under the Waste Bureau. They reflected that their
processing had been affected by REDISA as they took away their tire supply, however, due to
the incomplete collection they were still able to access tyres.
As discussed in this section the integration of existing actors in the informal sector varied
depending on the type of actor. Tyre transporters existing in the informal sector were integrated
into the waste tyre system, however participants did not report receiving some of the promised
supports of loans and mentorship. Micro-collectors were left out of the original writing of the
plan, but they did come to be included in the operation of waste tyre system. Some existing
waste collectors were integrated as micro-collectors although many did not participate due to the
low fee paid per tyre and the requirement that they register. Processors from the informal sector
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do not seem to have been integrated into the waste tyre system as those without proper licensing
were not supported by REDISA.
4.6 Business Creation
Aside from the goals of job creation, the REDISA plan also set out to establish businesses
and in particular Small, Medium and Micro Enterprises (SMMEs). Actors at the depot,
transporter and micro-collector level raised concerns over their ability maintain their enterprise
given the restrictions that were placed on them by REDISA. The enterprises were all threatened
by the low incomes they received and the lack of authority they had to expand and improve their
business.
4.6.1 Depots
At the depot level, participants described that they are given a flat rate for their operation of the
depot. One depot manager spoke of how the flat-rate limited their business, as they were not
incentivized to being more productive or efficient.
“Also, I think if maybe they said, you know preprocessing activities such as bailing, if
they perhaps, you know remunerated you according to how much you produced. Because
that also challenges the individual to say, okay guys, if we can manage to do 100 bails in
two weeks, or something. That guarantees us a certain amount of income. You know. But
the second you set everything at a standard rate, as a standard price. Whether you
produce according to how much they have asked you to produce, or whether you produce
less, it actually makes no difference, because you know you are going to get that same
amount every single month. …
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I mean, I think that was what REDISA had said to the department that they want to
create SMMEs and I guess businesses that can become sustainable on their own. But the
second you limit someone from being able to think out of the box or creatively or
challenge them. I mean you are just creating an employee, that must just meet the
deadline and they get paid the same salary. It’s not really creating a business at the end of
the day.” – Depot 41
In line with the above statement, a few depot managers requested that there should be a way for
them to generate an income and improve their businesses.
“Find a way for use to generate an income or give us a decent figure that we can at least
say right. So, we can do something, we can grow the business, we can improve, we can
buy decent furniture, we can buy things that we need at the depot. … Find a way to
generate income. Either open up a small processing plant on the depot, so we could also
crumble and sell it, make some money off of that.” – Depot 20
Participants described that under REDISA more of their expenses were paid for directly by
REDISA, such as purchasing wire for their bailing machines, or hiring security. Additionally,
participants reported that if they incurred an extra expense, for example servicing of fire
equipment or repair of a broken forklift, REDISA would have covered the invoice. One
participant described that when they became responsible for paying for their own bailing wire,
they went from producing 40-45 bails of tyres a day to just 15, which again demonstrates why it
would make sense to compensate depots for work done. One participant reported that having
these things covered by REDISA eased their financial stress. However, similar to the payment
of a flat-rate another participant felt when REDISA paid for these expenses it removed
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responsibility for these functions from the depots. This participant questioned if this made sense
when they were supposed to be operating as a business.
4.6.2 Transporters
Transporters also complained about a lack of income. This was felt to be generally low,
but also, as the participant below explains, didn’t increase in line with increasing costs such as
diesel prices and greater distances traveled to depots.
“Look we’ve been [transporting tyres] for 6 years or for 5 years, and the rate never
increased. And the diesel increased. When we started diesel [was] 7 rand, and now it’s 14
rand. So, I just, in the beginning I helped them a lot, and after that, they just said, just go
help me there, and I said no, no. It’s not worthwhile. It’s better for my truck to just stand
there, then send it down there. … The staff and the maintenance on the truck and stuff,
it’s just not worth it.” – Tyre Dealer/Transporter33
Transporters businesses were also restricted from growth as the dealers from which they
were to collect were allocated by REDISA. All transporters were also paid different rates for
delivering tyres to the depots. I remain unclear how this rate was calculated, however, one
transporter reported that when they left their transporting business it went from a majority black-
owned company to 100% black-owned company and their rate per kilogram nearly doubled, so
BEE must have been a component.
One participant explained how these varied rates meant they had to work far more than
another transporter in order to receive the same pay. They described that this was done to
equalize pay across all transporters, however this then act as a deterrent to expanding your
business as your rate might be decreased to equalize your pay with other transporters. The
participant described wondering what changes could be made so they could work less and earn
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more and described below. Similar to depot operators these practices limited the growth and
development of enterprises.
“REDISA had a little structure, where I didn’t agree with it. All the transporters need to
earn the same money. But at that stage, I was running my company on a big scale. Where
I would have 4 trucks on the road, I would have about 20, 16 guys working for me, and
then um… And they want me to tell that, I need, the next transporter needs to earn the
same what I am earning. But the other transporter, got the one bakkie and one trailer. It’s
just him and one helper on that bakkie that collects tyres. And you know for him, ‘oh, I
can start 9 o’clock in the morning, I finish by 3 o’clock, I’ve got what I want.’ Whereas
my company was running, 6 o’clock in the morning my drivers was here to take the loads
away…
And there was one point where I was still in that company, and I said, look, I don’t see
any growth, any further for me in this company, at REDISA, I think that I hit the ceiling
here now. Give me the amount of tyres that I must bring it, to earn the same as that man.
Give me that. Then you take my guys and you empower them, give them half of my
work, give him half of my work, then they can do it. Or take from, I’ll give you from my
dealers.” – Transporter 19
4.6.3 Micro-collectors
All micro-collectors interview expressed that they would like to receive a higher rate per
tyre. Initially, REDISA was paying micro-collectors 2 rand per tyre, and by the time they ceased
operations this rate had risen to 4 rand per tyre. However, micro-collectors were also limited as
to the number of tyres that they could collect in a month and when micro-collectors were earning
4 rand per tyre this limit was set at 750 tyres (DEA, 2018a). In a document provided by REDISA
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management, it is explained that this was done to limit the income micro-collectors could receive
because if they earned more they would have to register as taxpayers (REDISA, n.d.). This
provision taken so that micro-collectors would not have to pay taxes points to the continued
informality of their work. When the Waste Bureau took over, they increased the pay per tyre to 6
rand and the monthly quota to 1000 tyres, thus the monthly earning went up to 6000 rand (421
USD) (DEA, 2018a).
Based on the rates at the end of the REDISA plan, micro-collectors would have been able
to earn a maximum of 3000 rand (210.00 USD) per month (4 rand per tyre x 750 tyres). In June
2018, South Africa passed a new minimum wage which was 20 rand (1.40 USD) per hour, which
was widely protested for being too low (Crabtree & Turak, 2018). Considering an 8hr work day
and 22 working days in a month, this would amount to a minimum wage of 3,520 rand (247
USD) per month. This means that micro-collectors were earning approximately the minimum
wage. However, what is also important to understand about micro-collectors is that they require
transportation to get tyres to the depot. Again, if we consider 750 tyres collected in a month with
22 working days that would mean that micro-collectors need to collect 34 tyres per day to meet
the monthly quota. As a micro-collector describes with regards to the 6000 rand paid by the
Waste Bureau, not only does this require transportation, but many micro-collectors have others
who are working with them as well.
“You see that is why I say the 6000 is not enough. If this guy has got tyres, because he is
registered with REDISA for example, and then he has to collect tyres, but then he has got
people who are collecting for him… After that they get paid, and then you only get 6000
rand, how are you going to do that. It’s not only about paying them, it about also looking
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at the transport, maintenance and all those things. So, 6000 isn’t enough.” – Micro-
collector 38
One micro-collector described how they are grateful for the opportunity to make money, but still
understands that the pay they received in the system is not fair.
“No you see, the REDISA side is the first people I can say thank you to them. To
REDISA, because I didn’t knew about this type of industry, REDISA introduced us to
this type of industry. Secondly, REDISA didn’t work fair with us, I don’t want to lie, they
didn’t work fair with us. Because even in terms of payment, the problem it was the
payment.
When we meet the Waste Bureau, we see a lot of changes even the payment got better
than the payment we got from REDISA. So, we don’t even, we understand that REDISA
was just killing us. We collect tyres, we people are tyre collectors. You see that kind of
tyre, it is us, we collecting tyres. And REDISA is supposed to give us better, because the
people who are doing more job is us. They just sitting there in the office and playing with
the laptops and everything and then while we are outside. … Only to find out with
REDISA, one guy paid one million per month*. How can someone get a million per
month while you are getting 700 per month? This was totally really unfair.” - Micro-
collector 23
*Note: no individual was paid 1 million per month, however, in May 2017 the CEO’s
monthly salary was determined to be 347,000.00 rand (24,334 USD) (MEA vs. REDISA,
2017).
The collector who didn’t become involved with REDISA also felt that the price paid per tyre was
too low:
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“They just came and say no, we are going to take tyres and so on. But nothing was so,
nobody was so interested in doing that, because of the prices. Normally we go with where
the higher prices are. Yes because, as we selling them as steel, they would give us 1.50,
1.80 per kilo. Then you come and say one tyre is 2 rand, whether it’s big or small. … It’s
like playing, collecting, collecting, and then you go, 2 rand, 2 rand, 2 rand. It’s better to
sell inside a bag, because you can’t count them. You just burn them, then you go and sell.
… Because you have to hire a transport to get there. Whether it’s a van or a big truck you
have to pay a lot of money. So what if you don’t even get that kind of money, because of
tyres.” – Micro-collector 30
As an indication that the amount they were earning was not sufficient, some micro-collectors
also reported doing other work. One micro-collector laughed when I asked if waste tyres were
their main breadwinner or source of income. They reflected that from tyres they earn very little
compared to the other waste that they collect. Another participant described that they had an
additional business and that those who worked with them had other work as well. However, the
micro-depot administrator stated that waste tyres were their only source of income and they
thought that those delivering tyres to their micro-depot were also only collecting waste tyres as a
source of income.
The REDISA plan created a framework for the creation of SMMEs and many enterprises
were formalized and established under the plan. However, these businesses were discouraged
from expanding or improving due to flat-rates paid and quotas on the amount they could earn in
a month. At the depot level, participants reported that they were paid a flat-fee for work done and
were prevented from earning additional income. This discouraged depots from innovating to
improve or expand their business. Transporters reported similarly that the depots they serviced,
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and their incomes were determined by REDISA and therefore they were discouraged from
improving their business. Further, participants at both the transporters and micro-collector levels
reported that the income they received was too little in order to sustain and improve their
business.
4.7 Supports for Processors
As has been discussed above, a lack of processing was identified by most participants as
being a problem with the waste tyre system under the REDISA plan. As a means to promote
more processing, REDISA offered two main incentives, first, they offered a free supply of tyres,
and secondly, they offered a subsidy for some of those processing tyres. These efforts can also be
seen as supports for job creation as to create jobs in the processing sector, successful businesses
need to be established. Additionally, in collaboration with various Universities, REDISA
undertook research with regards to waste tyres processing in South Africa (REDISA, 2015a).
Where supports were identified as being lacking was with regards to meeting the legislative
requirements for processing, although some participants questioned whether this was an area in
which REDISA could or should assist.
While the REDISA plan called for recycling processors to be predominantly BBBEE
entrepreneurs, one participant felt that tyre processing was not an environment for SMMEs due
to the knowledge and expertise required. However, to encourage the establishment of SMMEs,
there were also provisions within the plan for REDISA to incubate businesses with capital for
new machines or equipment, however, none of the interview participants were part of this
incubation process.
“We’ve got very mature legislation in terms of all types of EIAs [Environmental Impact
Assessments] and things that. So, there’s a big hurdle. And a massive legislative hurdle.
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… It’s unfortunately not well suited for SMME’s. It’s just too complex. The legislation is
too mature, it just won’t work. So that hurdle makes it very difficult for these things to
just start up.” – Processor 26
4.7.1 Supply
In terms of the supply of tyres, some participants were already sourcing tyres outside of
the waste tyre management plan. Many participants spoke about how this happened, as well as
the relative ease of getting a supply of tyres. People were willing to give their waste tyres and
one processor reported getting paid to process tyres prior to the REDISA legislation, as described
below:
“Before REDISA we actually got [tyres] from places that do retreading, from transporters
that just don’t want their tyres because they are now scrap and they don’t have anywhere
to put them. So, they bring them to us for recycling. … They were actually happy to get
rid of them, and they would pay … I think it was 90 cents a kilo for recycling.” –
Processor16
When REDISA started it formalized the collection and supply of waste tyres and
provided them to processors for free. Many said that the supply of tyres through REDISA had
improved their business as they no longer had to source their own tyres or be involved in the
transportation of tyres. Two participants also reported that the supply of tyres through the
REDISA plan had been an incentive for them to spend the capital to begin processing tyres, as
they would not have been willing to source their own tyres.
“[Without a tyre supply from REDISA], we would have just continued collecting our
own tyres to a limited extent. And obviously I don’t think we would have been able to get
to the stage where we are now, if we were involved for the transportation and that sort of
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thing, because right now we are consuming a large volume of tyres and we certainly
wouldn’t have had the infrastructure to collect those tyres from all over….” – Processor
40
For any tyre recycler, the supply of tyres is the resource on which their business relies as
described by this participant:
“Yes. Because that is one of your risk factors in setting up your business, because the
business fails if you can’t get tyres. So, people want that… that is why also the Waste
Bureau, they also committed to that. You can apply now through the tender process, you
get a 5-year contract, with a renewable option, all financers look for that. There is two
things there, the supply contract, and the offtake agreements for the products. Because
either of the two, you haven’t got a business.” – Processor 34
One processor feared that as more processors are introduced, the demand for tyres may exceed
the supply. While there currently seems to be an abundance of tyres available, the actual
numbers are still unclear, and this was suggested as an area for further research. Additionally,
there is a fear that the waste tyre management plan may collapse. Due to these factors many
processors spoke about ensuring their businesses future by having alternative sources of tyres
such as historical stockpiles.
4.7.2 Subsidy
The subsidy offered by REDISA to processors was another incentive to encourage the
processing of tyres, however not all processors received the subsidy. One processor reported that
their ownership of their company was not 51% black and therefore their BEE level was not
sufficient, and they were denied a subsidy from REDISA. In the adjudication process described
in the REDISA plan BBBEE is to be taken into consideration when awarding contracts, but it
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does not explicitly say that companies are required to be majority black-owned. This decision
can be seen to support principles of BEE and the upliftment of PDIs that was being attempted
under the plan, however, in terms of the environmental goals of processing waste tyres, it seems
detrimental to undermine existing businesses. The cement kilns interviewed also described
difficult negotiations with REDISA around the subsidy and one of reported that they did not
receive any subsidy. Some agreed that it was appropriate for the subsidy to be negotiated on an
individual basis, especially considering the REDISA was trying to establish SMMEs in the
processing role.
“What I think should happen though, is that, I do think that it needs to be a bit more of
an adaptive approach. So maybe not across the board, so I think every company has to be
looked at. If it’s an SMME, a small to medium enterprise business that’s just starting out.
You know for job creations and things like that, and it’s a BEE owned company. Then
the tyre plan goes okay, you guys get paid 200 rand, 400 rand etc. as a gate fee for their
operations.
But if you are a, sort of a large multinational sort of tyre, cement manufacturer, where the
tyres that you are getting, especially if they are already chipped and shredded, they are
nice. The tyres that you are getting you can literally take those and substitute them ton for
ton with coal, and maybe taking half a ton of tyres to replace two tons of coal. So for
them, getting it for free, or even paying a slight fee for them, they would still see the
benefit of it. I think right now, they are actually getting off a lot more benefit than the
smaller guys who are trying to start up businesses.” – Waste Management 37
Some processors reflected that they would like to receive a higher subsidy, and a few
raised the issue that compared to other parts of the system, they were allocated a relatively small
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portion of the tyre levy. Under the REDISA plan, processors were allocated 13.5% while
transporters were allocated 38% (REDISA, 2012; see also Table 2). Some participants expressed
that they would carry on business without the subsidy and others felt that the subsidy was a
requirement in order to carry on their business.
One participant raised the issue that the subsidy not only helps processors to maintain a
viable business but it also helps them to be competitive in global markets. Especially because
many countries globally have EPR schemes or similar for tyre recycling that also subsidize
recycling. This participant reflected that the South Africa subsidy is quite low compare to other
locations and that because of this you can still import rubber crumb for lower cost than you can
produce it in South Africa.
4.7.3 Processing in South Africa
Many participants reported that tyre processing in South Africa is different than
elsewhere in the world. The first challenge identified was the poor quality of tyres compared to
other places. Participants reported that waste tyres in South Africa are far more worn and often
seem to have more steel than rubber. Participants from rubber crumbing processors described
that because there is less rubber on the tyre some processors were unable to meet the expected
outputs as they were projected based on the quality of tyres abroad. Some participants also
reported that it was difficult to find a market for the steel that was recovered as they could not
remove all traces of rubber from the product.
Participants also explained that technology solutions don’t work in South Africa due to
financial constraints, and therefore the South African solution needs to be tailored to South
Africa’s strengths, as is described below:
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“And the first world economy, the first world technology doesn’t work here, because it’s
too expensive. So you need to work with, use what works in the SA environment. And in
the SA environment we have a strong metals and mining sector, so there’s a lot of
knowledge, and a lot of maintenance and welders and guys like that, come from that
field, you can play to that strength and they are all out of work right now. You’ve got
high labour contingent, so automation doesn’t necessarily make a lot sense. And we have,
I think we have a South African willingness to work, to make something work. And I
think, those factors make a certain technology work here. Within the confines of a very
mature legislation, whereas other 3rd world countries don’t necessarily have that.” –
Processor 26
In a similar regard, some participants reported that the technology that was being used in
South Africa was either not appropriate or obsolete. One participant described how machines that
had been bought by REDISA were not explicitly for tyre recycling, but for recycling generally,
and therefore the machines never worked properly. While this calls into question whether
REDISA would be able to assist in determining appropriate technologies, it also highlights the
need for a strong understanding of what appropriate technology is and the challenges that
processors face when purchasing equipment. Below a participant describes that people were
taken advantage of and sold technologies that were obsolete or that quickly broke down and
reflected that this was an area where REDISA could be of assistance to ensure that viable
technologies were purchased.
“It’s obsolete technology, people just wanted to make money. And then they bought this
machinery, they started operating, only to find that it is obsolete technology. It’s no
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longer being used in those countries. And they fail, and the technology stops functioning,
they don’t have assistance from those countries to help them.
So I think that is the main, main problem of that, that is why it was important for
REDISA to assist in terms of the viability of the technologies that different people
bought, to be able to function, the process to continue to be there.” – Depot 28
A few participants also noted that REDISA did not provide any support to processors in
terms of finding or developing a market for their products. As some participants point out,
although recycling could be increased, there still needs to be a market for the recycled products.
“And the processing side of the business was never set up. And also, more importantly
the secondary processing side what not developed in this country at all. And I think that
is one thing the Waste Bureau will find, is that it is one thing processing tyres, but what
you do with processed material once it’s made available is another problem that one has
to solve.” – Processor 40
These are areas in which some suggested that REDISA may be able to help through research
focused on tyre processing in South Africa, and this was also part of the REDISA plan
(REDISA, 2012). In their 2015 Annual Report, REDISA highlighted that they had “initiated 22
research programmes and granted 14 bursaries to postgraduate students participating in the
respective projects at Stellenbosch and Nelson Mandela Metropolitan University” (REDISA,
2015a: 3). REDISA was also establishing a Product Testing Institute, were it was envisioned that
rubber products would receive an environmental rating to try and move manufacturing of rubber
products towards a circular economy (REDISA, 2015a). A few participants spoke about research
having been initiated by REDISA, however, reflected that given the length of time that research
takes, they had not yet felt the benefits of those efforts.
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4.7.4 Legislative Requirements
Some participants felt that the strict environmental legislation in South Africa is the
reason why some processors had failed, and most saw it as a difficult hurdle for new processors
to overcome. Many participants also described the challenges presented by South Africa’s
legislation for processors due to the complexity of the process, the time required, and the
associated costs as discussed in the quotes below.
“Because, you go and spend, just under the EIA [Environmental Impact Assessment] and
the license application, about 600,000 rand, before you can start doing anything with it.
And so, you and know, and it all adds up too, you have to purchase or lease the property,
because the license is property specific, and you cannot transfer the license to other
property, you start the process over.” – Processor 34
“Ya, so at the moment it is difficult and time consuming to get permits and environmental
authorizations. To either be a tyre pre-processor or an end sort of, tyre recovery, recovery
plant. I think number 1 our legislation is not very defined, so it is a little bit vague
around the edges, I mean if you had to look to see where pyrolysis and gasification fit
into our current Waste Act, and Air Quality Emission Act, and what standards you
actually need to meet. You can kind of read… If you are optimistic you read it one way,
if you are pessimistic you read it another way, so you are kind of not sure where to go
there, and because of that it also slows down the whole process as well. That, and the fact
that, I think our, just in general, in terms of getting out our permits and legislations and
licensed and getting final approval on EIA [Environmental Impact Assessment] in South
Africa, it does take a long time, it does take 3-4 years.” – Waste Management 37
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Aside from the challenges presented by the legislative requirements, there was little consensus
among participants on how this could be addressed. Some participants voiced their support for
the strong legislation and the protection of the environment that it secured, others however felt
that the legislation was too strict and that it should be eased. This was an area where some
identified that the DEA could have acted to assist new processors through the legislative process.
Similarly, many felt that the REDISA plan should offer more supports to processors to meet
those legislative requirements, whereas others felt that it was not an area where REDISA should
have intervened.
“I think the biggest frustration that a lot of people felt was that they didn’t understand the
legislative requirements of processing. So SMMEs would start up some kind of
processing and they would run into EIA [Environmental Impact Assessment] hurdles,
things like that, and they would say it was REDISA fault, or this thing isn’t working.
And, whereas, at this [processor] I mean we had a similar, this [processor] has a similar
set of challenges, but it comes with the territory and I think SMMEs just don’t understand
that. So, I think a lot of the frustration was ill directed maybe.” – Processor 26
“I mean the whole mandate of DEA was actually to set up and to develop this industry, so
you would have thought that those barriers to entry would have been eliminated, and the
bureaucracy and all the red tape that’s involved in obtaining those licenses would have
been made easier. But at that stage is certainly wasn’t. And I think potentially REDISA
could have helped, but I am not sure what relationship they had with the DEA in order to
facilitate that kind of thing. But certainly, it would have made a difference.”– Processor
40
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“And I knew of a couple recyclers that did put up recycling plants, and they didn’t help
them to get their EIA and those things together, they just left them, go get that stuff, then
we will help you. There was enough money for them to help them.” – Tyre Dealer/
Transporter 33
Processors were supported under the REDISA plan through receiving a free supply of
tyres, and in some cases a subsidy for their processing of waste tyres. Despite these supports, a
lack of processing was a common criticism of the REDISA plan and it calls into question what
more could have been done to assist new entrants at the processor level. Participants described
that areas where REDISA could have been more supportive were in determining appropriate
technology for processing in South Africa and in meeting the legislative requirements for
opening a processing facility. REDISA had made steps towards addressing processing in the
South African context by funding research through various Universities, however, given the
length of time that the program was running the research did not yet benefits participants. As will
be discussed in the sustainability section below the lack of processing threatened the entire waste
tyre system and more processing needs to be established in order to match the supply of waste
tyres arising in South Africa.
4.8 Sustainability
As a way of assessing the value of the jobs created, I tried to understand if they were
sustainable. In considering this it is important to consider if the system as a whole is sustainable,
as all the jobs in the system rely on the viability of the system as a whole. A participant from
REDISA’s management stated that as long as there is a PRO present and funding the system the
jobs are not sustainable. In their view the goal of the EPR system is not to continuously have to
fund all parts of the waste tyre system, but instead to establish a value chain that is self-
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sufficient. A self-sufficient value chain would be one in which the value of the processors
product would fund the rest of the system from collection to transportation to the processing
facility. In this understanding, EPR is used to fund the incubation of the waste tyre system until it
is self-sufficient. Another participant spoke of this as they described that the REDISA plans
purpose was to create an industry and that if the industry was viable, then environmental and job
creation goals of the program would be met, as cited below.
“But to answer your question to say, that there are two things to be achieved, which is the
environmental aspect of recycling tyres and then the job creation. That is true and correct,
but I think in between those two, there is an industry that is being created. And that is
what excited us … to get involved. So, when you create an industry, which is number one
sustainable, then it is sort of imperative that jobs will be created.” – Processor 07
Another participant described the balance that needs to be achieved between supply and demand
of waste tyres for the industry to be sustainable.
“So, if you just look at supply and demand of tyres in South Africa. They really have to
understand the demand. Because it is no use doing all the great things, collecting all the
tyres, and then you sit with a supply that is increasing exponentially and your demand is
not. So, what is the demand that we have now, how can we build it? And if we do build it
to its maximum capacity, what would that maximum capacity be, and does that maximum
capacity cover what our, what the supply is on a yearly basis? Because then you have got
a sustainable model, the moment your demand is less than your supply, your model is not
sustainable.” – Waste Management 37
Participants discussed the challenges facing the sustainability of the system as well as
their own business. The first problem identified was a lack of processors for tyres which caused a
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backlog, the effects of which were experienced through the system from depot, to transporter to
micro-collector. Another problem that participants identified was an uncertainty with regards to
the longevity of the system which limited the investment actors were willing or able to make in
the system.
4.8.1 Lack of Processing
The lack of processing for tyres, which is a significant issue itself, also became a large
issue for the depots. As per the Waste Tyre Regulations, there are limits to how high tyres can be
stacked and the distance that must be kept between piles (RSA, 2009). This means that without
enough offtake of tyres to processors, the depots become full and risk non-compliance with the
regulation which could result in fines or closing depots. In a presentation, the Waste Bureau
outlined that in October 2017 at least 15 of depots operating were non-compliant for various
reasons, including not meeting the Waste Tyre Regulation, fire regulations and stormwater
regulations (DEA, 2018a). In the quote below, one depot manager described their concerns due
to non-compliance of their depot.
“Overcapacity, so I’m non-compliant. So there the problem is, you know that, in this
country, if you are non-complaint, your fine is from, between 60,000 and 200,000. We
don’t have an allocation in the budget for that… So, if I have to get a fine like that, I
would have to close the business. I will have to become insolvent, because there’s no way
I’ll be able to pay it. So that would be jail time for me.” – Depot 20
The viability of transporters businesses has also been threatened by the lack of space in the
depot. When the depots are full, transporters are not allowed to deliver loads to the depots and
this meant that the transporters were not working everyday and were also limited to the amount
of tyres that they could deliver. Some transporters described how they were forced to let go of
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staff because of the lack of work. This then also trickles down as a problem to the dealers that
they service as they are forced to stockpile tyres in an unsafe way which becomes a health and
safety risk. Some transporters also spoke about how this affected relationships, in some cases
decades old, which they had built up with tyre dealers.
“Now, you’ve got a guy, the worker that works for you, what do you do? You put him
off, you cannot pay them for the full week if you only work 3 days. A lot of the
transporters lost drivers, a lot of the transporters lost workers. So, what do they do now,
they are all just run casual workers. Only work day by day. There’s not much
responsibility for them.” – Transporter 19
“[The dealers] said ‘We don’t work right, we don’t collect, why didn’t they come, we
come around they only take a few tyres.’ But we must take from everybody something,
so that we can, so they can see we are there. So now we must take like that, today we can
do them, but if there is still left, you must leave it, I must go to the other guy, I can’t
finish here… And it’s a certain time in every month, we already know about that,
everybody knows about that, when it’s peak time, or when is it normal. But we know
them, and they know us. They know we know when to go. We build a relationship with
them and now suddenly were busy breaking it down.” – Transporter 15
Some micro-collectors were also affected by the lack of processing and resulting lack of space at
the depot as described by the quote below. One micro-collector reported that because the tyre
transporters were not coming as frequently, they were working slower to avoid the risk of having
too many tyres piled outside their micro-depot. However, the micro-depot manager who was
interviewed reported that because so many people are servicing their micro-depot, the
transporters do continue to come. This was echoed by one participant from a depot who said that
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they tried to maintain space for collections from micro-collectors as waste tyres was their
livelihood.
“The tyres we are collecting everyday, everyday collection. Not unless the depot, it will
depend on the depot, if the depot is full, so it’s a slow going. It’s a go-slow project now.
Because the depot is full. So we can’t collect tyres while the trucks will not come and
take, so that it will pile and pile and pile and then we are under risk.” – Micro-collector
23
4.8.2 Longevity
Another threat to the system is the longevity of it. Under REDISA, because it was only
gazetted to be a 5-year plan and then subject to renewal, REDISA could not guarantee contracts
for a long period of time and this limited the business security for actors in the waste tyre system.
This seemed to affect transporters the most, who reported that initially they were given one-
month contracts, which were extended gradually until the final contracts they receive from
REDISA were for 3 years. However, these final contracts were not completed as REDISA ceased
operations shortly thereafter. The short-term contracts affected transporters who were seeking to
buy new vehicles to expand their businesses but were unable to secure necessary loans without a
longer contract. One transporter explained:
“Because that relationship between REDISA and government, they also didn’t know,
look they can’t say, guys, I’m going to give you a 5-year contract. Because for us to have
decent vehicles or something, we need to go to the bank with something, okay this is a 5-
year contract, I need a truck of that size, you can see this is the money that I am going to
earn, I will be able to pay that. Okay, things like that. REDISA couldn’t give that.” –
Transporter 19
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The sense of security in the tyre system has been shaken numerous times through the
establishment of the EPR scheme. Before REDISA had started operations, the gazetting of the
plan faced numerous legal challenges which created confusion and uncertainty in the industry
(DEA, 2012). The stability of the waste tyre system was again affected when the DEA sought to
have REDISA liquidated. Many described a sense of unease as they were unsure of the future of
the waste tyre system and how that would affect their business. Actors within the system
continue to experience this as the DEA has again called for new plans to be submitted signalling
that the system with again come under new management. One participant explained:
“We didn’t know the Waste Bureau was going to start up, so end of REDISA it was a bit
of a concern, obviously. Now, I don’t think it is a concern because the Waste Bureau is
doing a great job. But we don’t know who the next guys are, we don’t know how they are
going to run. We don’t know, we don’t even have the surety that they will take our
contracts over. We don’t know their process and I don’t think they are at a point where
they can figure that process out yet. I think it’s still too early for them. But it puts a lot of
uncertainty in the whole thing. And all we know, that’s what we are banking on, is the
Minister has said that they will make this thing work. So, I mean that’s the only word that
you can bank on. And if the Minister disappears, now the next Minister says, you know,
I’m not going to do this. Ya, I mean, it’s very, very uncertain.” – Processor 26
Some of the contracts that had been established under the REDISA plan were not carried over to
the Waste Bureau, and this raised concerns over management under a future PRO as well. In
some cases, participants explained that they had agreements with REDISA that had not been
formalized in contracts, and the Waste Bureau refused to continue with the agreements. One
participant explained how he had to restart negotiations with the Waste Bureau.
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“Because it took us the better part of 2 years to get REDISA, and get the negotiations
finalized and get the agreement signed with them. And then we did it for 3 months, and
then REDISA got liquidated. And when we, first discussion with the Waste Bureau we
were back at square one. Exactly where we started with REDISA.” – Processor 31
Currently the Waste Bureau has asked people at all levels of the system to tender for new
contracts, even for micro-collectors. Many participants described how this gave them cause for
concern as anyone in South Africa could apply, and their tender could easily be thrown out in
case of problems. This requirement has been especially hard on transporters many of whom are
used to working in informal situations as well as depot managers who may not have operated a
business before.
“I need to really tender, put a tender in for my contract. And that is a little bit of a worry
for us, because that is what REDISA didn’t put us up, how to do that. Although
government is trying now to say, guys you don’t have to worry, just put in this tender. If
you are already here we want to help to remain and things like that. They had a workshop
now, a couple of weeks ago, to educate us, how to tender for this thing. We will see how
it works out.” – Transporter 19
Another factor affecting the longevity of the waste tyre management plan, is the insecurity of the
funding. Many participants welcomed the change to have the levy collected and distributed
through the National Treasury as a way to reduce the likelihood of corrupt spending. However,
others raised concerns around the funds not being properly ring-fenced and being spent on other
budget priorities rather than on the waste tyre system. This was seen previously with the plastic
bag levy, where only 7% of the funds collected went towards the recycling of plastic bags
(Nahman, 2010).
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The sustainability of the REDISA plan and the jobs within it were threatened by a lack of
processing capacity for waste tyres, and by uncertainty surrounding the IIWTMP. Without
enough processors the entire waste tyre system was threatened as depots became full and non-
compliant with Waste Tyre Regulations, transporters could no longer work full-time to collect
and deliver tyres to depots and micro-collectors were forced to slow their collection due to a
reduction in the frequency of collection from their micro-depots. This indicates that the system
created cannot yet support the supply of waste tyres that exists in South Africa. This threatens
the system as a whole because if the system cannot sustain the level of work being done by
transporters and micro-collectors they may be forced to remove themselves from the system or
reduce their earnings. Additionally, without assurances of long-term stability actors are unable or
unwilling to invest capital into the waste tyre industry. This lack of investment threatens the
sustainability of businesses and the waste tyre system.
4.9 Summary of Findings
As I previously described, through a dialectical understanding, a lens of political ecology
allows us to see that waste tyres do not simply exist, but that they have been constructed as a
hazard, a resource and now, through the EPR legislation, a governable object. Further, political
ecology encourages us to understand that the costs and benefits associated with these
constructions of waste tyres are distributed unequally and that they act in relation to existing
social and economic inequalities and that this has political implications for the power of actors
within the system (Bryant and Bailey 1997, 28-29 as cited in Robbins, 2012).
In order to summarize my finding I have considered the above results in relation to the
different constructions of waste tyres. I have analyzed the costs and benefits associated with
these constructions for actors in different roles in the waste system. In this way, I hope to
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understand how the different ways in which tyres are considered, either in positive or negative
light, is dependent on the power dynamics in existence.
Prior to the REDISA plan, waste tyres in South Africa were conceived of as a hazard and
as a resource. I will discuss both of these constructions of waste tyres briefly before considering
the costs and benefits of the construction of waste tyres as a governable object which this
research has focused on. Political ecology highlights that the political motivation for the
REDISA plan led to the focus on employment and particularly upliftment of PDIs; however,
despite this focus, power within the plan was not given to the actors within the system. Instead,
those that were uplifted had little autonomy to determine how their businesses were run or
supported and the power within the system stayed with REDISA.
4.9.1 Waste Tyres as a Hazard
After their useful life as a vital component of transport vehicles, which allow for the
movement of both people and products, waste tyres are of very little use to their consumers.
Waste tyres in the environment create a fire hazard and a health risk (Park et al., 2018; Phale,
2005; Muzenda & Popa, 2015). In addition to these hazardous properties of waste tyres the
government, through the Waste Tyre Regulation ensured their classification as a hazardous waste
(RSA, 2009).
The greatest cost of the characterization of waste tyres as a hazard falls onto those who
have the tyres when they become waste. In South Africa this is most often the tyre dealer, who
would accept old tyres in exchange for new tyres when making a sale. However, as discussed in
this research, the tyre dealers also had a way of passing this hazard on to tyre transporters. These
tyre transporters came to tyre dealers seeking tyres that could be resold either as second-hand
tyres or as retreads but were often required to take the unusable waste tyres from the dealers.
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Tyre transporters, especially during apartheid, had little access to other work and participants
reflected that they had little choice but to take the waste tyres.
Once the tyre left the dealership, it could either be reused, or disposed of. Some tyre
collectors, and in some cases dealers themselves would take waste tyres to a local landfill and
pay a fee to dump the tyres there legally. However, this fee was prohibitive in many cases and
instead tyres were disposed of in the environment (Phale, 2005). Thus, the cost of the waste tyre
would be passed back to South Africans as a whole as the waste tyre became a hazard in the
environment. This can also create a cost for government as they may be required to clear the
illegal dumpsite.
In some cases, tyres would be kept by the consumers who used them, and there are large
existing stockpiles of mining, passenger and truck tyres in South Africa (REDISA, 2012; Phale,
2005). Similar to tyres dumped in the environment, these historic stockpiles of tyres pose health
and fire risks, however, where ownership of the tyres is known the owner remains responsible
for these costs (REDISA, 2012).
4.9.2 Waste Tyres are a Resource
Prior to the REDISA legislation, waste tyres had already been recognized as a resource.
The earliest constructions of waste tyres as a resource come from those who use them in
secondary industry to manufacture shoe soles, furniture, animal feeders, playground swings and
ladders, and planters (REDISA, 2012).
Tyres are also a resource for steel, and it is common for tyres to be burnt to recover the
steel they contain (Muzenda & Popa, 2015; REDISA, 2012). The steel is then taken and sold to a
scrap dealer for a small profit (REDISA, 2012). Burning tyres is also used as a way for people to
stay warm where other sources of heating are too expensive (Muzenda & Popa, 2015; DEA,
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2012). All forms of burning waste tyres in the open cause hazards as chemicals are released from
the tyres and can have negative health effects on the nearby environment and individuals (DEA,
2012). While the means of disposal comes with risks, these burning practices do benefit society
through the economic gains of those carrying out the activities, and the removal of waste tyres
from the environment.
Waste tyres also came to be seen as an exportable resource in international markets. This
exporting provides benefits to those who are exporting tyres. However, when the resource is
removed from South Africa it eliminates the chance of it driving economic growth within the
country. Ultimately this costs South Africans that potential for economic growth while instead
benefiting the country to which it is imported.
Prior to the REDISA plan waste tyres had also become a resource for more formalized
industry such as tyre crumbing and fuel to cement kilns (Nkosi et al., 2013). This was happening
at a relatively small scale and these industries only processed 4% of waste tyres arising in South
Africa (REDISA, 2015a). Additionally, despite waste tyres being a resource for their processes,
as discussed in this research, processors remained reluctant to pay for the resource. Instead
owners of waste tyres stockpiles were willing to supply these processors with the resource either
by transporting and/or paying for the waste tyre to be processed. This benefited both the owner
of waste tyres, who was no longer responsible for the hazard of tyre stockpiles and the tyre
processor who received their input resource for free.
In South Africa the waste tyres themselves proved a challenge for processors as they did
not recycle well. Many processors in this study described that the quality of the South African
waste tyre that they were receiving was more worn that tyres processed elsewhere, and this
prevented them from getting the expected yields out of their equipment. In this way the waste
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tyres were, according Robbins (2012), insurgents to their classification as a resource and became
a cost to processors, as they did not necessarily comply to the desires of humans.
4.9.3 Waste Tyres as a Governable Object
Despite waste tyres being used as a resource in the ways described above, the demand for
waste tyres did not match the supply and waste tyres stockpiles were still growing and created a
hazard to the health and environment of South Africans. The government benefitted from the
characterization of waste tyres as a hazard as it allowed them to call for waste tyres to be
governed. It also allowed the government to make producers and importers of tyres carry the
costs of the hazardous waste tyre, rather then governments. Under the REDISA plan, the
manufacturers and importers of tyres were responsible for funding the waste tyre system through
the tyre levy, although this fee was likely passed on through the dealer and finally to the end
consumer.
The REDISA plan became to tool through which waste tyres were constructed and
controlled as a governable object. Under the REDISA plan, not only did waste tyres become an
object to be governed to address the environmental hazard they presented, but waste tyres were
to be used as a resource to drive job creation in South Africa. The legacy of apartheid and high
unemployment in South Africa drove the need for the solution to the environmental problem of
waste tyres to also be used to create employment for PDIs. In order to achieve this, the REDISA
plan created a regulated system for the collection, transportation, storage and processing of waste
tyres, and prescribed who was allowed to handle tyres at every stage of the system.
The first to benefit from the REDISA plan were the tyre dealers and other owners of
waste tyres as the cost of waste tyres was removed from them, and instead put onto the
management of the REDISA plan. The legislation also limited dealers as they were forced to
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subscribe to the REDISA plan due to the government decision not to approve any of the other
plans which were submitted. This cost dealers having any discretion as to how tyres were
collected and became a problem for them when the depots became full and transporters could not
collect tyres are regularly.
As reported in this research, the tyre transporters also benefitted as their businesses were
formalized and they were now paid for waste tyres rather than charged for their disposal. With
this new source of income, many were able to hire additional people to work with them, as well
as buy new bakkies, trucks and trailers. However, many transporters later saw their business
decline as depots became full and they were forced to lay off employees and to pay for those
expensive vehicles. Furthermore, REDISA had control over the dealerships that they serviced
and the rate they were paid for collecting or distributing tyres, and this limited the potential
growth of transporters enterprises and their ability to adapt to sustain their businesses.
At the micro-collector level, a research participant found that their old practices of
burning tyres to recover steel was more worthwhile that the fee that the REDISA plan would pay
them for collecting tyres, in this way REDISA failed to address the environmental hazard
associated with burning tyres. The new construction of waste tyres as a governable object did
benefit others who found that the fee was acceptable and began to collect waste tyres to be
turned in at micro-depots. As discussed in this research, while micro-collectors did earn under
the REDISA plan and therefore received financial benefits, their pay was minimal for the work
performed. The main beneficiaries of the creation of a role within the waste tyre system for
micro-collectors seems to have been REDISA, who counted them towards the politically
motivated goal of job creation. The government then took up this benefit and was also able to
claim a role in job creation that was reported as a positive outcome of the IIWTMP.
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Another benefit that was realized under the REDISA plan was the creation of waste tyre
depots as this was a new type of business that had not existed. These facilities were used to
stockpile tyres in a controlled way according to the Waste Tyre Regulations, so that the risks
associated with storing tyres could be minimized (RSA, 2009). However as reported in this
research, when REDISA failed to ensure adequate processing was established to remove the
waste tyres from the depot and the depots were faced with the problem of how to maintain
compliance with legislation and the consequences if they did not.
Many of the processors of waste tyres benefited through the governing of waste tyres as
they were guaranteed a supply of their resource. However as described by a research participant,
for those who did not meet the requirements to work under the REDISA plan, they saw their
supply of tyres taken away as it was not longer cost effective to for other actors to provide them
with tyres. Again, many benefitted from the subsidy that was allowed under the REDISA plan,
but not all were paid for processing tyres. The governing of waste tyres brought more actors into
the waste tyre system and this resulted in increased competition for some existing processors and
participants reported that no support was provided towards developing markets for their
products.
The government benefitted through the governing of waste tyres as they were able to
count and claim the job creation that was reported under the REDISA plan as being the result of
a government initiative. The jobs created under the REDISA plan brought the government closer
to its National Development Plan targets and encourage political support for the ANC party.
Additionally, through removing tyres from the environment the government also benefits from
the reduced health risks.
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Despite the benefits for various actors, much of the power within this system remained
with REDISA’s management. They determined who was awarded contracts at all levels of the
system, as well as determining the income that actors would receive. The lack of power was
evident at the micro-collector, transporter and depots levels where enterprises did not have
autonomy regarding the work that they did or the income that they received. Further, REDISA
were able to exclude actors from the system by restricting participation to registered actors. This
was a cost to individuals at all levels of the system as without registration and a contract they
could not receive a fee for returning tyres to micro-depots or depots and they could not receive a
supply of tyres or tyres for processing.
Finally, the perceived poor governance of waste tyres when REDISA was exposed in the
media for mismanagement challenged the characterization of tyres as a governable object as they
became associated with corruption and uncertainty (Comrie, 2018; Mathews, 2017). Ultimately
this cost REDISA the authority to operate the plan, and the government displayed that they still
did have the highest power over the operation of the waste tyre management plan by seeking the
liquidation of REDISA. Additionally, the challenge to the characterization of waste tyres as a
governable object had negative effects on some of those working within the plan, such as tyre
transporters who had to work regain the trust of dealerships with whom they worked.
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Chapter 5 Conclusions
This research shows that South Africa has benefitted from the REDISA waste tyre
management plan. Since the introduction of the plan collection and recycling of waste tyres has
increased, and progress has been made towards the first goal of diminishing the environmental
burden of waste tyres. Additionally, the plan has created recognizable benefits at all levels of the
waste tyre system in terms of job creation. There is still a lot of room for growth in both the
collection and processing of waste tyres in South Africa, as diversion from landfill targets for
2018/2019 are set at just 50% of waste tyres arising (DEA, 2018b). The successes associated
with the REDISA plan indicates that further development of the waste tyre system would benefit
from an extended producer responsibility scheme to fund to expansion of the collection and
processing of waste tyres. Despite these benefits, there are some areas where the implementation
of the plan could have been improved.
Through the REDISA plan, the waste tyre levy was used to fund employment and create
business opportunities at all levels of the waste tyre system. Despite these opportunities the
number of jobs created was far less than the 10,000 jobs that were projected. As highlighted
through the lens of political ecology, this projection was likely an overestimation due to the
political pressures around job creation in South Africa. This focus on employment detracted from
attention paid to the environmental goals of the plan and seems to have diminished the overall
effectiveness of the plan in removing waste tyres from the environment.
As a means to address the political goals of job creation in South Africa, the REDISA plan
adopted the principles of BEE. BEE prescribes that jobs and business opportunities should be
created for those who were previously disadvantaged. There is evidence in this research that
BEE principles were considered when recruiting participants and entering into contracts with
131
businesses. However, concerns were raised that some appointments were political rather than in
direct support of BEE. Additionally, the recruitment practices that REDISA used do not seem to
have followed their adjudication process. Instead it seems that many actors came to work under
the REDISA plan through relationships with other who were already working with REDISA, and
this calls into question the fairness of recruitment under the plan.
In an EPR scheme that was established with the goal of uplifting PDIs it is notable that the
most marginalized labourers in the waste sector, being waste pickers, were largely forgotten in
the original writing of the REDISA plan. This calls into question what power they had both in
the shaping of the plan and subsequent to its implementation. The exclusion of waste pickers
indicates that they were not conceived of as beneficiaries of the governing of waste tyres.
Even after waste pickers were added to the plan as micro-collectors, the REDISA plan
does not appear to have been effective at incorporating existing waste pickers into the waste
tyres system. The most common complaint from micro-collectors that might inform this
deficiency is low incomes. Due to the low pay received, I think it is worth considering whether
to opportunities created for micro-collectors should be considered a job. Instead I think that
REDISA added another waste stream that can be collected in South Africa without creating
meaningful work. However, through their requirements that individuals register, they restricted
access to the benefits of this waste stream to a small group of individuals and excluded existing
actors from the informal sector. This is similar to the effects of privatization of landfills
discussed by Samson (2009, 2015), where existing actors lost access to waste resources at those
sites. Despite the low pay received there are many micro-collectors working in the waste tyre
system, however, this does not mean that the wage they are receiving is fair, or that it is enough
to sustain themselves. It is important to consider that Viljoen et al., (2016) found that most street
132
waste pickers in South Africa are doing so due to lack of choice or opportunity to find other
work. If micro-collectors are to be considered as having employment, I would argue that the
REDISA plan was exploiting them as minimally paid workers in order to meet their targets for
job creation.
An area where the REDISA plan seems to have succeeded is through the integration of actors
from the informal sector at the tyre transporter level. These transporters were required to register
their businesses to pay the required taxes which brought them into a formalized system.
Additionally, transporters businesses grew and most acquired more vehicles which allowed them
to hire more employees. Despite the success that the plan did have at integrating tyre collectors,
there are still existing informal transporters working outside of the plan and therefore there is
potential for more integration. More research needs to be done to understand why those informal
transporters were not integrated.
In terms of supports that transporters received, participants reported some training from
REDISA with regards to administrative requirements of the plan. One transporter also reported
that REDISA helped him through the processes of registering his business for tax purposes.
Additional supports that were described in the REDISA plan, being mentorship and loans, do not
seem to have been forthcoming.
One way to improve the REDISA plan would be to remove restrictions on actors within
the system that limit their growth and prevent them from expanding their businesses. Rather than
receiving a flat monthly fee, depots could be paid based on the volumes of tyres they distribute to
processors as is done with depots in Portugal (Ferrão et al.,2008). Depots could also take on
more roles, such as pre-processing, to enable them to increase their income and develop their
business. Similarly, the income received by transporters and micro-collectors should not be
133
subject to limits. This would motivate and allow these actors to expand and develop their
enterprises and improve their situations. While these limits could be seen as a way of enabling
more individuals to enter the system and preventing dominance by a few individuals, I think that
the resulting limits to growth reduce the benefits that actors within the system could obtain.
Under the REDISA plan, the actors remain employees, whose work it dictated, rather than
SMMEs who are independent and can innovate to ensure the sustainability of their businesses.
Another improvement to the REDISA plan would be to prioritize processing. Without the
establishment of enough processors for waste tyres, the sustainability of the entire system and the
jobs within have been threatened. A lack of processing has diminished the functioning of depots,
transporters and micro-collectors and has decreased the viability of enterprises at all these levels.
While processors were offered a free supply of tyres and in some cases provided a subsidy, to
date, this has been insufficient to drive enough development of processors. As reported by
participants, complying with legislative requirements to become a tyre processor in South Africa
is a lengthily process and requires substantive funding, and REDISA did not attempt support
processors in overcoming this hurdle. Additionally, some existing processors operating in the
informal sector were excluded from receiving tyres due to incomplete licensing and more could
have been done to integrate them into the system. Many processors reported that waste tyre
processing in South Africa had different challenges due to the quality of tyre, and that some
processing technology purchased was ineffective. The technological challenges and the
legislative hurdle affected the ability of new entrants to process waste tyres to maintain the waste
tyre system. Especially where REDISA was seeking to create black-owned SMMEs at the
processor level these are areas where more supports could have been provided.
134
Consideration also needs to be given to whether tyres should continue to be exported to
increase the sustainability of the waste tyre system. REDISA maintained a flow of tyre through
the system with exports; however, this removes the potential of using those waste tyres as a
resource for further job creation or to sustain processors into the future. All efforts should be
made to keep tyres in South Africa rather than exporting, as this allows for the maximum
benefits in terms of job creation, as well as keeping the resource in the economy. Before
exporting tyres, cement kilns should be considered as viable processors and supported. Cement
kilns, and other energy recovery technologies, are currently not seen as ideal processor as the
materials contained in tyres are lost; however, given their low environmental impacts (Corti,
2004) and that participants from cement kilns reported that processing tyres created jobs at their
businesses, they should be considered.
Another threat to the sustainability of the waste tyre system was a general lack of
stability. The REDISA plan was only approved for 5 years and then subject to renewal by the
government, and this limit the length of contracts that REDISA could provide to actors with the
system. As describe in this research, a lack of long-term contracts discourages investment in
capital for processors and also affected some participants ability to obtain loans to fund their
business needs. Many factors reduced certainty in the system, including the 5-year time frame
and the legal challenges to the plan at the outset. However, the most destabilizing was when
REDISA ceased to operate, and it became unclear whether there would be a new manager for the
plan, or if the existing contracts would be taken on. In an effort to reduce this instability in the
future, better monitoring and evaluation of the PRO should be undertaken so that issues can be
detected and resolved more quickly.
135
Given the problems that arose through the REDISA plan, the most important thing for
any EPR scheme in South Africa will be oversight of the program. Fishbein (2002) stipulated
that a successful EPR system needs meaningful targets for collection and recycling and needs to
differentiate recycling from waste-to-energy processing. In the context of the REDISA plan, I
would add targets for job creation, and if it is to continue, targets for exports should also be
distinguished from recycling and waste-to-energy processes. Fishbein (2002) also insists on
reporting requirements and enforcement mechanism. Here in particular the REDISA plan seems
to have failed, as the DEA described challenges in obtaining information from REDISA
regarding their progress towards meeting targets (PCEA, 2017). The government also had little
means to address unmet targets beyond withdrawing support for the plan, which again
destabilizes the system (PCEA, 2017).
In addition to more oversight by government, actors within the system could be involved
in additional monitoring of the PRO, as was done in Portugal where producers, retreaders and
rubber industrialist held shares in the PRO (Ferrão et al.,2008). In the South African waste tyre
system, the producers and manufacturers that fund the program could be involved, or different
actors who are funded through the program. Additionally, given the goals of job creation, I think
that oversight should extend beyond the collection and processing of tyres, and consider
recruitment and adjudication processes particularly with regards to the incubation process. This
could help eliminate concerns over the political nature of some appointments.
In the South Africa context, I think that there are benefits to having a PRO manage EPR
schemes. Since the Waste Bureau has been managing the REDISA plan for almost a year, there
is now experience of how it can be operated under a government body. The Waste Bureau has
been successful in its management of the plan, but it has been criticized by some participants for
136
being too slow and bureaucratic. Moreover, I think that the Waste Bureau’s requirement that all
actors under the waste tyre system tender for their contracts is unreasonable and threatens to
exclude the previously disadvantaged individuals and SMMEs which have been targeted for
upliftment. Using a PRO can circumvent the bureaucracy that is inherent in government as has
been found with other waste management services in South Africa (Godfrey et al., 2013).
Another reason for there to be a PRO managing the plan is to maintain separation between the
regulator and actors in the system, which is important for oversight.
This research demonstrates that EPR can be used to drive economic growth and increase
employment. Through funding the waste tyre system in South Africa, the REDISA plan
facilitated the growth of the industry around waste tyres. However, if EPR is to be used to drive
job creation this case study points to some potential challenges that need to be considered. Some
of these challenges reflect the unique case in South Africa, where opportunities were targeted at
those who were previously disadvantaged, however, they could apply equally to any EPR
scheme that is seeking to drive job creation.
Firstly, the recruitment of actors should be consistent and transparent, and opportunities
should be created and supported equitably. Secondly, when integrating marginalized actors, it is
important to ensure that they are being compensated fairly and supported to improve their
enterprises. Similarly, businesses that are created under an EPR scheme need to have
independence from the PRO in decision making around business growth and development.
Additionally, processors need to be supported in their development phase rather than only once
they are established in order to maintain the sustainability of the system through ensuring
adequate processing capacity. Finally, to maintain the stability of the system, oversight needs to
be comprehensive and clear targets with enforcement mechanisms need to be determined.
137
Works Cited
Akenji, L., Hotta, Y., Bengtsson, M., & Hayashi, S. (2011). EPR policies for electronics in
developing Asia: an adapted phase-in approach. Waste Management & Research, 29(9), 919–
930. https://doi.org/10.1177/0734242X11414458
Baudouin, A., Bjerkli, C., Habtemariam, Y., & Chekole, Z. F. (2010). Between neglect and control:
Questioning partnerships and the integration of informal actors in public solid waste
management in Addis Ababa, Ethiopia. African Studies Quarterly, 11(2/3), 29.
Black, P. A. (2005). On the case for “Black Economic Empowerment” in South Africa. South African
Journal of Economics, 70(8), 1148–1162. https://doi.org/10.1111/j.1813-6982.2002.tb00061.x
Bryant, R. L. (1998). Power, knowledge and political ecology in the third world: a review. Progress
in Physical Geography, 22(1), 79–94.
Cahan, S. F., & van Staden, C. J. (2009). Black economic empowerment, legitimacy and the value
added statement: evidence from post-apartheid South Africa. Accounting & Finance, 49(1), 37–
58. https://doi.org/10.1111/j.1467-629X.2008.00280.x
Corti, A. (2004). End life tyres: Alternative final disposal processes compared by LCA. Energy,
29(12–15), 2089–2108. https://doi.org/10.1016/j.energy.2004.03.014
Comrie, S. (2015, December 20) Probe into how R1.1bn in tyre levies was spent. City News.
Retrieved from https://city-press.news24.com/Business/probe-into-how-r11bn-in-tyre-levies-
was-spent-20151220
Crabtree, J. & Turak, N. (2018, June 1) South Africa's new minimum wage is the 'beginning of a long,
difficult process,' finance minister says. CNBC News. Retrieved from:
https://www.cnbc.com/2018/06/01/south-africa-minimum-wage-the-beginning-of-a-difficult-
process-finance-minister-nene.html
Department of Environmental Affairs (DEA) (2008) National Waste Management Strategy- Phase 2
Research. Retrieved from
http://www.groundwork.org.za/archives/2009/NWMS_strategic_issues.pdf
Department of Environmental Affairs (DEA) (2012, December 20) Department of Environmental
Affairs announces the Resumption of the REDISA plan implementation [Press Release].
Retrieved from https://www.environment.gov.za/content/resumption_redisa_plan
Department of Environmental Affairs (DEA) (2013, February 26). Industry Waste Management Plan.
PowerPoint presented to the Portfolio Committee on Waste and Environmental Affairs.
Retrieved from https://pmg.org.za/files/docs/130226iwmp.ppt
138
Department of Environmental Affairs (DEA) (2017, May 2). Department of Environmental Affairs
2017/18 Annual Performance Plan - Overview by the Director-General. PowerPoint presented to
the Portfolio Committee on Environmental Affairs. Retrieved from
https://pmg.org.za/files/170502DEA_Overview.pptx
Department of Environmental Affairs (DEA) (2018a, March 6) Waste Tyre Collection and Recycling.
PowerPoint presented to the Portfolio Committee on Environmental Affairs.
Department of Environmental Affairs (DEA) (2018b, April 17). Targets for Diversion of Waste Tyres
from Landfill. PowerPoint.
Department of Environmental Affairs (DEA) (2018c, May 22) PCEA Presentation. PowerPoint
presented to the Portfolio Committee on Environmental Affairs.
Department of Trade and Industry (DTI) (2007). Background to, Intention & Application of the Codes
of Good Practice. Retrieved from
https://www.thedti.gov.za/economic_empowerment/docs/Inside.pdf on July 26, 2018.
European Tyre and Rubber Manufacturer’s Association (ETRMA). (2015) End-of-life Tyre Report
2015. Retrieved from http://www.etrma.org/uploads/Modules/Documentsmanager/elt-report-
v9a---final.pdf
Ferrão, P., Ribeiro, P., & Silva, P. (2008). A management system for end-of-life tyres: A Portuguese
case study. Waste Management, 28(3), 604–614. https://doi.org/10.1016/j.wasman.2007.02.033
Fishbein, B. (2002). Waste in the Wireless World: The Challenge of Cell Phones. NewYork:
INFORM Inc. Retrieved from: http://infohouse.p2ric.org/ref/19/18713.htm on August 22, 2018.
Godfrey, L., & Oelofse, S. (2017). Historical Review of Waste Management and Recycling in South
Africa. Resources, 6(4), 57. https://doi.org/10.3390/resources6040057
Godfrey, L., Muswema, A., Strydom, W., Mamafa, T., & Mapako, M. (2017). Co-operatives as a
development mechanism to support job creation and sustainable waste management in South
Africa. Sustainability Science, 12(5), 799–812. https://doi.org/10.1007/s11625-017-0442-4
Godfrey, L., Scott, D., & Trois, C. (2013). Caught between the global economy and local
bureaucracy: the barriers to good waste management practice in South Africa. Waste
Management & Research, 31(3), 295–305.
Gupt, Y., & Sahay, S. (2015). Review of extended producer responsibility: A case study approach.
Waste Management & Research, 33(7), 595–611.
Hobson, K. (2016). Closing the loop or squaring the circle? Locating generative spaces for the
circular economy. Progress in Human Geography, 40(1), 88–104.
https://doi.org/10.1177/030913251456634
139
iSolveit Consulting. (2017). Final Report: Key Findings Emanating from the Performance Review of
REDISA NPC. Retrieved from: http://sawic.environment.gov.za/documents/7215.pdf. Accessed
Dec 3, 2017.
Jacob, P., Kashyap, P., Suparat, T., & Visvanathan, C. (2014). Dealing with emerging waste streams:
Used tyre assessment in Thailand using material flow analysis. Waste Management & Research,
32(9), 918–926.
Karaağaç, B., Ercan Kalkan, M., & Deniz, V. (2017). End of life tyre management: Turkey case.
Journal of Material Cycles and Waste Management, 19(1), 577–584.
https://doi.org/10.1007/s10163-015-0427-2
Kojima, M., Yoshida, A., & Sasaki, S. (2009). Difficulties in applying extended producer
responsibility policies in developing countries: case studies in e-waste recycling in China and
Thailand. Journal of Material Cycles and Waste Management, 11(3), 263–269.
https://doi.org/10.1007/s10163-009-0240-x
Lazarevic, D., & Valve, H. (2017). Narrating expectations for the circular economy: Towards a
common and contested European transition. Energy Research & Social Science, 31, 60–69.
https://doi.org/10.1016/j.erss.2017.05.006
Li, X., Xu, H., Gao, Y., & Tao, Y. (2010). Comparison of end-of-life tire treatment technologies: A
Chinese case study. Waste Management, 30(11), 2235–2246.
https://doi.org/10.1016/j.wasman.2010.06.006
Manomaivibool, P. (2009). Extended producer responsibility in a non-OECD context: The
management of waste electrical and electronic equipment in India. Resources, Conservation and
Recycling, 53(3), 136–144. https://doi.org/10.1016/j.resconrec.2008.10.003
Mathews, C. (2017, July 20) Tyre recycling: why government wants Redisa liquidated. Financial
Mail. Retrieved from https://www.businesslive.co.za/fm/fm-fox/2017-07-20-tyre-recycling-why-
government-wants-redisa-liquidated/
McFarlane C., & Waibel, M. (2012) in Urban Informalities, “Introduction – The Informal-formal
Divide in Context”, Routledge, 2012, p. 1-12.
Milanez, B., & Bührs, T. (2009). Extended producer responsibility in Brazil: the case of tyre waste.
Journal of Cleaner Production, 17(6), 608–615. https://doi.org/10.1016/j.jclepro.2008.10.004
Minister of Environmental Affairs (MEA) v. REDISA. (2017a). Order of J. Cloete, June 1, 2017.
Retrieved from:
https://www.environment.gov.za/mediarelease/highcourtgrants_molewaordertowinddownandliqu
idateredisa. Accessed Dec 3, 2017.
140
Minister of Environmental Affairs (MEA) v. REDISA and Minister of Environmental Affairs v.
Kusaga Taka Consulting. (2017b). Judgement of J. Henney, September 15, 2017. Retrieved
from: http://www.saflii.org/za/cases/ZAWCHC/2017/106.html. Accessed Dec 3, 2017
Miraftab, F. (2004). Neoliberalism and casualization of public sector services: the case of waste
collection services in Cape Town, South Africa. International Journal of Urban and Regional
Research, 28(4), 874–892. https://doi.org/10.1111/j.0309-1317.2004.00557.x
Miraftab, F. (2012). Colonial Present: Legacies of the Past in Contemporary Urban Practices in Cape
Town, South Africa. Journal of Planning History, 11(4), 283–307.
https://doi.org/10.1177/1538513212447924
Muzenda, E. & Popa, C. (2015). Waste Tyre Management in Gauteng, South Africa: Government,
Industry and Community Perceptions. International Journal of Environmental Science and
Development, Vol. 6, No. 4, April 2015
Nahman, A. (2010). Extended producer responsibility for packaging waste in South Africa: Current
approaches and lessons learned. Resources, Conservation and Recycling, 54(3), 155–162.
https://doi.org/10.1016/j.resconrec.2009.07.006
Nahman, A., & Godfrey, L. (2010). Economic instruments for solid waste management in South
Africa: Opportunities and constraints. Resources, Conservation and Recycling, 54(8), 521–531.
https://doi.org/10.1016/j.resconrec.2009.10.009
Nkomo, M. (1981). The Contradictions of Bantu Education. Harvard Educational Review, 51(1),
126–138. https://doi.org/10.17763/haer.51.1.n46465n1m5301q83
Nkosi, N., Muzenda, E., & Zvimba, J. (2013). An Analysis of the Waste Tyre Management Plans in
South Africa. In Proc. IIE Int’l Conference Proceedings of International Conference on
Innovation in Engineering and Technology (pp. 108–114)
Nnorom, I. C., & Osibanjo, O. (2008). Overview of electronic waste (e-waste) management practices
and legislations, and their poor applications in the developing countries. Resources,
Conservation and Recycling, 52(6), 843–858. https://doi.org/10.1016/j.resconrec.2008.01.004
Ntobela, T., (2015, June 14) Recycling Industry Rewarded at REDISA Recognition Awards. Sandton
Chronicle Retrieved from: https://sandtonchronicle.co.za/119662/recycling-industry-rewarded-
at-redisa-recognition-awards/
OECD (2016). Extended Producer Responsibility. Organisation for Economic Co-operation and
Development Publishing. https://doi.org/10.1787/9789264256385-en
Ortíz-Rodríguez, O., Ocampo-Duque, W., & Duque-Salazar, L. (2017). Environmental Impact of
End-of-Life Tires: Life Cycle Assessment Comparison of Three Scenarios from a Case Study in
Valle Del Cauca, Colombia. Energies, 10(12), 2117. https://doi.org/10.3390/en10122117
141
Park, J., Díaz-Posada, N., & Mejía-Dugand, S. (2018). Challenges in implementing the extended
producer responsibility in an emerging economy: The end-of-life tire management in Colombia.
Journal of Cleaner Production, 189, 754–762. https://doi.org/10.1016/j.jclepro.2018.04.058
Parliament of the Republic of South Africa (2018, April 18) “Targets for Diverting Waste Tyres from
Landfill Sites” Retrieved from http://pmg-assets.s3-website-eu-west-
1.amazonaws.com/180417Waste_Tyre.pdf
Phale, A.R., (2005) Environmental Impact and Waste Management of Used Tyres in RSA Master’s in
Environmental Management, University of Johannesburg, Johannesburg, South Africa.
Pickren, G. (2014). Geographies of E-waste: Towards a Political Ecology Approach to E-waste and
Digital Technologies: Political Ecology E-waste. Geography Compass, 8(2), 111–124.
https://doi.org/10.1111/gec3.12115
Portfolio Committee on Environmental Affairs (PCEA) (2017, October 17). REDISA liquidation;
Waste Tyre Plan; Waste Bureau: briefing with Minister. Retrieved from
https://pmg.org.za/committee-meeting/25224/
Reddy, R. N. (2016). Reimagining e-waste circuits: calculation, mobile policies, and the move to
urban mining in Global South cities. Urban Geography, 37(1), 57–76.
https://doi.org/10.1080/02723638.2015.1046710
REDISA. (2012). Integrated Industry Waste Tyre Management Plan of the Recycling and Economic
Development Initiative of South Africa. Government Gazette. Vol. 569, No. 35927 (1-56)
REDISA. (2015a). Annual Report, 2015. Retrieved from:
http://www.redisa.org.za/Satellite/000161%20-%20REDISA%20Annual%20Report%20v5.pdf.
Accessed Dec 3, 2017.
REDISA (2015b). Response to the Carte Blanche aired on Sunday 15 Nov. Retrieved from:
http://fliphtml5.com/khjf/awkg/basic
REDISA (n.d.) “Jobs and Job Reporting”, Unpublished report, REDISA, 21 Dreyer Street, Claremont,
7708, South Africa.
Republic of South Africa. (1989). Environmental Conservation Act No. 73 of 1989. Government
Gazette. (No.11927)
Republic of South Africa. (1996). South African Constitution Act No. 180 of 1996, Section 24.
Government Gazette.
Republic of South Africa. (1998). National Environmental Management Act No. 107 of 1998.
Government Gazette. (No. 19519)
142
Republic of South Africa. (2003). Broad-Based Black Economic Empowerment Act No. 53 of 2003.
Government Gazette.
Republic of South Africa. (2008). National Environmental Management: Waste Act No. 859 of 2008.
Government Gazette. (No. 32000)
Republic of South Africa. (2009). Waste Tyre Regulations. Government Gazette. (No. 31901)
Republic of South Africa. (2012). National Waste Management Strategy. Government Gazette.
Republic of South Africa. (2016). National Pricing Strategy for Waste Management. Government
Gazette. (No. 40200)
Republic of South Africa & National Planning Commission. (2012). Our future: make it work :
national development plan, 2030. Pretoria: National Planning Commission.
Robbins, P. 2012. (2nd Edition). Political Ecology: A Critical Introduction. Malden: Blackwell.
Rogerson, C M (2000) Emerging from apartheid's shadow: South Africa's informal economy. Journal
of International Affairs; Spring 2000; 53, No. 2; (673-
Roy A (2005) Urban informality: Toward an epistemology of planning. Journal of the American
Planning Association 71(2): 147- 158
Samson, M. (2009). Wasted citizenship? Reclaimers and the privatised expansion of the public
sphere. Africa Development, 34(3–4).
Samson, M. (2015). Accumulation by dispossession and the informal economy – Struggles over
knowledge, being and waste at a Soweto garbage dump. Environment and Planning D: Society
and Space, 33(5), 813–830. https://doi.org/10.1177/0263775815600058
Southall, R. (2007). Ten Propositions about Black Economic Empowerment in South Africa. Review
of African Political Economy, 34(111) 67-84. Retrieved from
http://www.jstor.org/stable/20406363
Stull, V., Bell, M. M., & Ncwadi, M. (2016). Environmental apartheid: Eco-health and rural
marginalization in South Africa. Journal of Rural Studies, 47, 369–380.
https://doi.org/10.1016/j.jrurstud.2016.04.004
Sweet, Justine (2018, April 26) The (un)certainty of taxes: Is the 1 January 2019 implementation date
for carbon tax possible? LexisNexis. Retrieved from https://www.golegal.co.za/implementation-
date-carbon-tax/, accessed on July 27, 2018.
Tangri, R. and Southall R. (2008) The Politics of Black Economic Empowerment in South Africa.
Journal of Southern African Studies, Volume 34, Number 3, September 2008. Retrieved on
November 14, 2011.
143
Tyre Waste Abatement & Minimization Initiative of South Africa (TWAMISA). (2017, December
30). “Consultation process undertaken by Tyre Waste Abatement & Minimization Initiative of
South Africa (“TWAMISA”) for the Draft TWAMISA Industry Waste Tyre Management Plan
(“IWTMP”)”. Letter to Minister of Environmental Affairs. Retrieved from:
http://sawic.environment.gov.za/?menu=348
Uruburu, Á., Ponce-Cueto, E., Cobo-Benita, J. R., & Ordieres-Meré, J. (2013). The new challenges of
end-of-life tyres management systems: A Spanish case study. Waste Management, 33(3), 679–
688. https://doi.org/10.1016/j.wasman.2012.09.006
United Nations Conference on the Human Environment (1992) Rio Declaration on the Environment
and Development. Retrieved from http://www.unesco.org/education/pdf/RIO_E.PDF
Viljoen, K., Blaauw, P., & Schenck, R. (2016). “I would rather have a decent job”: Potential barriers
preventing street-waste pickers from improving their socio-economic conditions. South African
Journal of Economic and Management Sciences, 19(2). https://doi.org/10.17159/2222-
3436/2016/v19n2a2
Waste Management World (2015, June 24) Rolling Out Tyre Recycling Across South Africa. Waste
Management World Magazine. Retrieved from: https://waste-management-world.com/a/rolling-
out-tyre-recycling-across-south-africa
World Bank. (2017). South African Unemployment. Retrieved from:
https://data.worldbank.org/indicator/SL.UEM.TOTL.ZS?locations=ZA. Accessed Nov 29, 2017.
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Appendix A
May 1, 2018
Invitation to Participate
Dear Potential Participant,
I am a graduate student in the Department of Geography and Planning at the University of
Toronto in Canada. I am writing to you to invite you to participate in a research project I am
currently undertaking as part of the requirements for my degree.
My research project will be investigating how the REDISA Integrated Waste Tyre Management
Plan affected those working with waste tyres. I would like to learn where and for whom jobs
were created under the plan. I will also be exploring any changes to who handled waste tyres and
how tyres moved through the system. I am seeking research participants from various sectors of
the waste tyre system including dealers, sellers, recyclers, transporters, depot workers and
collectors. I would like to speak both to people who were working with waste tyres prior to the
legislation, and those who entered the system afterwards.
I will be in Western Cape province between April 2018 and June 2018 conducting interviews
throughout the province. Interviews will take approximately 1 hour and can be scheduled in a
location that in convenient for you. If you would prefer to conduct the interview in a language
other than English, please let me know and I will arrange an interpreter.
If you would like you to participate, or if you have any questions, I would be happy to hear from
you.
Thank you,
Sydney Baker
MA Candidate, Department of Geography and Planning
University of Toronto, Canada
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Appendix B
To the participants in this study,
As you have been made aware, the purpose of this study is to investigate how the REDISA
Integrated Waste Tyre Management Plan affected those working with waste tyres. You were
selected for participation in this study because of your involvement in the waste tyre system.
This work is being done under the supervision of Professor Thembela Kepe and Associate
Professor Virginia Maclaren of the University of Toronto. The data is being collected for the
purposes of a Master’s thesis and possibly for subsequent research articles.
You will be participating a face-to-face interview of approximately one hour. During the
interview you will be asked questions about your role within the waste tyre systems and any
changes that you observed under the REDISA plan. With your permission your interview will be
recorded and later transcribed. Hand written notes will also be taken throughout the interview. If
you want, your transcript will be sent to you to via email so that you can add any further
information or correct any misinterpretations.
The information obtained in the interview will be kept in strict confidence. All information will
be stored and reported in such a way that individual persons cannot be identified. The University
of Toronto Office of Research Ethics will have access to study data for quality assurance
purposes. All raw data (i.e. transcripts, interview notes) will be destroyed two years after the
completion of the study.
Your participation in this study is voluntary and you may at any time refuse to answer a question
or withdraw from the interview process. Up until 90 days after your interview, you may request
that any information, whether in written form or audiotape, be eliminated from the project. You
may request a summary of the findings of the study.
If you have any questions, you may contact myself or my supervisors, Dr. Kepe or Dr. Maclaren
using the contact information provided below. You may also contact the University’s Office of
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Research Ethics for questions about your rights as a research participant at
[email protected] or +1 416-946-3273.
Thank you in advance for your participation,
Sydney Baker
Thembela Kepe
Virginia Maclaren
By signing below, you are indicating that you are willing to participate in the study, you have
received a copy of this letter, and you are fully aware of the conditions above.
Name: _____________________________________
Signed: ____________________________________ Date: ______________________________
Please initial if you agree to have your interview audio taped: _____
Please initial if you would like to review a copy of your transcript: _____
Please initial if you would like a summary of the findings of the study upon completion: _____
Please keep a copy of this form for your records.
147
Appendix C
Consent - Master’s thesis and research articles - Recorded and transcribed - Information confidential, to be destroyed in 2 years - Voluntary, can withdraw or refuse to answer
Preliminary Questions (to be asked as appropriate depending on the participant):
Your name:
Position or Job Title:
Company/Enterprise:
How long have you been in this position? With this enterprise? Doing this work?
Year company was established:
Number of Employees or co-workers/collaborators:
What role does you/your enterprise play in the waste tyre system?
Interview Questions
Please describe how you/your company came to be involved in working with waste tyres.
- When?
- How did you learn about the opportunity?
- Did you receive any assistance to start your work/business?
- For new entrants: How did you hear about the REDISA plan?
- Did the introduction of the REDISA plan influence you or your companies’ interest in working with
waste tyres?
What changes did you noticed in the waste tyre system when the REDISA plan was introduced?
- Did anything change about the way you/your company worked within the waste tyre system?
- Changes in how tyres move through the system? Where or to whom you receive and distribute
tyres to?
- Do you know of anyone who used to work in the system, but doesn’t anymore?
- Why did these changes occur?
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What is your perception of the changes to employment under the REDISA plan?
- Did your employment change? Did your ability to make a living change?
- Did the number of employees in your company change?
- Did you notice any change with regards to other sectors in the waste tyre system?
- How many employees are in your company now? Under the REDISA plan? Under the Waste
Bureau?
- Is your business sustainable in its current form?
Why do you think the REDISA plan failed?
- How do you feel about the failure of the plan?
- What was positive about it? What was negative about it?
- Was it disruptive? How are things different with the current management by the Waste Bureau?
- Did the government have a role in its failure?
Do you think that the REDISA plan was a fair plan? Why, why not?
- Was there adequate consultation during its development?
- Did it disadvantage or advantage certain actors?
Would you like to see the plan come back?
- Why or why not?
- In what form?
- If you were to be the author of the new plan, what would you keep? What would you change?
Can you think of anyone else who should participate in this research?
- Informal actors?
- People no longer working with tyres?
Did you receive any training or support from REDISA in order to establish your business?
- Was there enough support?
How did you find it working with REDISA?
- Were there any challenges?
Did you BEE status affect your ability to work with them?