Combat Rancid Oil, But Avoid Damaging the Environment

Combat Rancid Oil, But Avoid Damaging the Environment
United Daily News editorial (Taipei, Taiwan, ROC)
A Translation
January 7, 2015

Executive Summary: The EPA waste cooking oil recycling program just went into effect on New Years day. But it has already run into problems. Food industry tycoon Kao Chi-ming of the Yi Mei company criticized the government's certification process for the recycling industry. He said its attempt to prevent the recycling of rancid cooking oil could encourage vendors to dump the oil into ditches, thereby polluting the environment. If government control of cooking oil recycling destroys the environment, the trade-off becomes deeply worrisome.

Full Text Below:

The EPA waste cooking oil recycling program just went into effect on New Years day. But it has already run into problems. Food industry tycoon Kao Chi-ming of the Yi Mei company criticized the government's certification process for the recycling industry. He said its attempt to prevent the recycling of rancid cooking oil could encourage vendors to dump the oil into ditches, thereby polluting the environment. If government control of cooking oil recycling destroys the environment, the trade-off becomes deeply worrisome.

Kao Chi-ming is hardly an alarmist. Restaurants and snack bars can be found everywhere on Taiwan. Conservative estimates put the amount of waste cooking oil produced annually at 70 to 80 thousand tons. The EPA registers less than 7,000 tons of recycled waste oil. That means that over 90% of the oil is unaccounted for. The EPA assumes that as long as it controls the source, and all recyclers are registered, the problem is solved. It assumes they can be tracked, the flow of oil can be controlled, and the recycling of rancid oil into cooking oil can be prevented. That is why it issues work permits and adopts a QR Code for auditing. These are all examples of a “Maginot mentality”.

But "source management" of waste cooking oil on Taiwan is no easy matter. The reality is grim. The sources are too many and too scattered. Every night market stall operator and hole in the wall shop creates waste oil. The government may try to manage the recycling industry. But it will find it impossible to cover all the market stalls. Moreover, even before the rancid oil scandal erupted, mechanisms for oil recovery already existed in the market place. Rancid cooking oil was sold to the "little bee" recycling industry or donated to pig farmers. Such recycling takes place regardless of what the price is or where the oil goes. In fact, it indirectly helps the community maintain a clean and healthy environment. Therefore it makes sense to recycle resources. One cannot repudiate this issue in one fell swoop.

To prevent rancid oil from getting back into the cooking oil market, the government must increase oversight over recyclers. But if increased government oversight leads to a breakdown in the waste oil recycling network, stall owners will indiscriminately dump waste oil in the sewers. This could lead to serious consequences. It could breed mosquitoes and cockroaches, impact neighborhood health, block drains, impede drainage, cause flooding. The discharge of rancid oil into the rivers and eventually the sea, could lead to the death of fish, plants, and animals. If it results in environmental disaster, the results would be unthinkable.

The job of the EPA is to protect the environment, to protect it against destruction. If the EPA's waste cooking oil recycling policies result in the destruction and deterioration of the environment, that would be robbing Peter to pay Paul. That would be shooting oneself in one's foot. There are three reasons for such decision-making blind spots. One. Administration officials are too close to the problem. They are bent on solving the recycled cooking oil problem, and have taken their eyes off the ball. Two. Bureaucratic inertia. Their heads are filled with thoughts about "official authority" and "management." They hope to master and control industry. But they have forgotten the need to go with the flow. Three. Linear thinking. They want to push a button and solve all problems in the most expedient manner possible. They lack any understanding of society and its complexity, of the need to unravel problems one by one, using different means in different cases.

In order to prevent vendors from cavalierly dumping waste oil, Kao Chi-ming's advice is for the government to set the price of oil high enough to ensure its recovery, then turn it into fuel. The extra cost can be made up with government subsidies. This is a much more feasible solution. Pricing oil high enough would prevent the oil from flowing every which way. It would encourage industry to actively recycle. Should China Petroleum fill this role? That can be discussed. Private sector firms more experienced in biodiesel production might be more suited to the task. That might be better than piling too many responsibilities onto China Petroleum. Government and industry should communicate with each other in order to find the best solution.

Allowing businesses to dump their oil in ditches would lead to environmental disaster. It would leave a mess that the government would have to spend even more money to clean up later. It would be better to use subsidies to turn that oil into a community resource. On balance, the latter clearly has lower social costs. Moreover, the situation is different in cities and counties all over Taiwan. Central government “one size fits all” solutions to the problem of waste oil recycling fails to consider differences in local conditions. It also lacks a phased implementation plan. It is difficult to be optimistic about the outcome. The EPA should practice source management. But it should also consult with the petroleum and refining industries. It should work with them to solve the problem of downstream oil problems.

Dayu tamed the waters. He allowed them to flow. He dredged nine rivers, allowing the flood waters to reach the sea. The EPA by contrast, has attempted to tame the rancid oil crisis by blocking it. It has adopted a "Maginot mentality." It has imposed strict controls on the recycling industry, and heavy fines on vendors and restaurants. The effectiveness of these measures is dubious. Worse still, it could damage to the environment. Can we afford not to take precautions?

大愚治油：切忌堵了廢油，卻壞了環境
2015-01-07 聯合報 社論

環保署廢食用油回收新制元旦甫上路，立即面臨挑戰。食品大廠義美總經理高志明批評，政府採發證方式管理回收業者，以為可收防堵效果，卻可能導致攤商將廢油直接倒進水溝，造成環境的汙染。若為管理食油，卻破壞了環境，這種顧此失彼的政策後果堪憂。

高志明的話，並非危言聳聽。台灣餐廳及小吃攤商林立，每年產生的廢食油保守估計達七、八萬噸，但環保署登記回收的廢油不到七千噸，亦即有九成以上流向不明。而環保署的想法，以為只要把握「從源管理」的原則，將所有回收業者列管，即可追蹤、掌握廢油之流向，防止業者利用回收油再製成黑心油出售。因此，核發工作證、採用QR Code供檢舉稽核，都是根據這套「防堵哲學」所設計出來的策略。

然而，台灣的廢食油不易「從源管理」，卻是嚴峻的事實。原因是，源頭太多、太散，每家夜市攤商、每個街邊小店都是產生廢油的來源；就算政府對回收業者的管理再嚴，也難以涵蓋所有攤商。再說，在黑心油事件發生前，民間原即存在一套自由市場的回收機制，或者將廢油賣給俗稱「小蜜蜂」的回收業者，或者摻入餿水免費送給養豬人家。這樣的回收工作，不論價格多少或去向如何，其實都間接幫助社會維護了環境的清潔與衛生，故而是有意義的資源再利用，不可一舉將它否定。

簡單地說，為避免廢油重新流入食油市場，政府對回收業者當然要加強管理，確保其流向無虞。但是，政府加強管理的結果，如果造成廢油回收網的破裂、斷鍊或失控，導致攤商業者將廢油任意傾倒於溝渠，那就可能引發嚴重的後遺症。例如，輕則帶來蚊蠅蟑螂，影響鄰里社區的衛生；重則引起溝渠阻塞、妨礙排水，引發區域水患；甚至是油汙隨著水流排向河川、進入大海，造成魚類或動植物的死亡。倘真造成環境的災難，後果不堪想像。

試想，環保署的主要職掌是在保護環境，使其免於遭到人為破壞；如果環保署制定的廢食油回收政策，結果卻會造成環境的破壞與惡化，這豈不是挖東牆、補西牆，自己搬石頭砸腳？之所以會出現這樣的決策盲點，原因有三：一是思考點距離問題太近，一心想解決食油問題，卻忘了其他的著眼；二是官僚慣性，滿腦子都是「官威」和「管理」，想要掌握及控制業者，卻忘了因勢利導；三是線性思考，以為有一種「按鈕模式」，可以用最省事的方法解決全部問題，卻不知社會現象的存在有其複雜度，需要抽絲剝繭去逐一釐清，利用不同手段去對付。

為避免攤商任意棄倒廢油，高志明的建議是，政府可以指定中油以保證價格回收，再製成燃油；多出的成本，可用政府預算給予補貼。這項建議，至少指出一個比較可行的方向：定價收購廢油，可以確保油的流向不會四處亂竄，有助鼓勵業者積極回收。至於中油是否扮演此一角色的最合適企業，其實可以再作討論；事實上，一些具有產製生質柴油經驗的民間廠商，也許更適合承擔這樣的任務，而不必讓中油包山包海地接受額外的政策任務。這點，則有待政府與業者從長溝通計議，找出最佳解決之道。

事實是，與其任由攤商業者將廢油棄倒水溝，釀成環境災難後再由政府花錢收拾，不如善用一些補貼機制，將廢油變成社會可利用的資源；兩相權衡，後者的社會成本顯然較低。再說，台灣各縣市的情況不同，中央企圖用一套簡單的指令解決廢油問題，卻不考慮各地的條件差異，也沒有分階段推進的計畫，其結果恐怕讓人難以樂觀。我們建議，環保署在推動源頭管理的同時，應該召集中油、油廠及相關回收業者協商，設法將中下游廢油的溢流及疏通問題一起解決。

大禹治水，是採取疏導的方式，疏通九河，把洪水引入大海。環保署治油，採取的則是「防堵思維」，嚴管回收業者，重罰攤商和餐廳，除了讓人擔心其成效，若更引起破壞環境之後遺症，則噬臍莫及，豈可不慎？