After collecting 50 butts from the street in front of a home obviously occupied by a smoker, I decided to put the following letter in the mailbox of the offending household. I enclosed the bag of butts with a note on it saying, 'Please put in your garbage'.

Dear Neighbours,

If you’re old enough to smoke, you’re old enough to clean up after yourself.  It shouldn’t be up to your neighbour to do it for you.  Yesterday I picked all these butts up off the ground in front of your home.  I found more this morning.

I’m trying to keep our street and community clean and free of litter.  Why am I picking up after you?  You are not a child.

These are ashtrays.  Please use them or one of your own, an empty jar, tin or can will do.  Stop littering your dirty, toxic butts on the street, please. I’m giving you these portable, reusable, extinguishing ashtrays free so that you can correct your behavior.  If you want more, call me if you can’t find your own ashtray.

I’m tired of picking up after the smoker(s) who live here.  By throwing your toxic cigarette filters on the ground you show disrespect and inconsideration and lack of pride for our beautiful neighbourhood.

Please be aware that the cigarette butt problem in front of your home is upsetting, polluting and has to stop.

Littering cigarette butts is against the law.  If you continue to dirty the street someone will be gathering evidence and reporting this problem to the city’s by-law enforcement division. 

​The fine for littering in Toronto is $325 per occurrence.

Whew! I made the December 3rd deadline, just under the wire. I put the final touches on my comments about changes to Ontario's cherished and much-emulated Blue Box recycling program. The proposed changes take recycling away from municipalities and puts it in the hands of "producers".  These are the corporate giants and their brands that create the waste materials in the first place. I put responding to the government committee whose members will be voting on this on my 'must do' list.  Proud to say must 'do' is now 'done'. A four-page, typewritten brief.

​The only tools I have are words.  Even then, I can't force politicians and policymakers to read or do what I say but at least I can say, "I told you so"  and "I tried."  Keep in mind that comments  won't be circulated if they mention names and phone numbers. I had to edit my submission to remove Loblaw, Shoppers Drug Mart, Life Brand and CEO Galen Weston from my comments about wet wipes. Yes, a big waste bin of topics are covered here. When you have the government's ear, bend it.

Ontarians have one of two choices about waste disposal, 1) be responsible and use the appropriate bin or 2) be irresponsible and litter or dump, and/or contaminate loads by recycling incorrectly and not packing their bins correctly.

This regulation covers 1) the responsible consumer who will put the waste in the appropriate bin.  It obligates producers to deal with the waste in the bin, by definition “end of life” waste.  However, the legislation has a gaping hole: it does not deal with point 2) above, the Ontarians who are careless with their waste.

I suggest that the term “end of life” be removed from the text of legislation wherever it appears.
Section 70 of this regulation says that it “may provide that a person mentioned in section 61 or 62 is responsible for implementing a promotion and education program in respect of the collection system or management system for that class in accordance with the prescribed requirements.”         (italics mine)
It mentions educating consumers. I completely agree – communication is a key. Let the public see how well or poorly corporations are doing at managing waste generated by both the responsible and irresponsible consumers.
This regulation speaks of:

• Reporting on the amounts of Blue Box materials supplied and diverted each year
• Establishing collection systems
• Achieving management requirements for Blue Box materials, including meeting diversion targets
• Educating consumers
• Registering with and reporting to the Resource Productivity and Recovery Authority
• Other requirements, including record keeping and third-party audits

 
Regarding, ‘Educating consumers’ I recommend a return to Ontario Regulation 103/94 2.1.3 and that this be an obligation placed on all sectors – Industrial, Commercial, Institutional, Multi-Residential – a holistic approach that takes recycling targets seriously across the board and communicates this message to the public.  Quoting here directly from the former regulation:

A Guide to Source Separation of Recyclable Materials for Industrial, Commercial and Institutional Sectors and Multi-Unit Residential Buildings

Information to Users

• To promote awareness of the source separation program and ensure its continuing success, information must be provided to those who will use the program (e.g. employees, patrons, students and tenants).
• This information can be in the form of yearly or more frequent progress reports that show the amount of materials collected, cost savings or other waste reduction achievements.
• These reports serve as reminders and motivational tools to encourage participation by providing feedback to users.
• The program should be communicated to employees, tenants, students and patrons to ensure that source separation procedures, responsibilities and equipment use are properly understood.
• New employees should also be informed of the program and trained in its operation as soon as is practical after being hired. Also, information about modifications to the program, such as the addition of new materials to be separated, must be conveyed.
• Communication can be through newsletters, signs, group meetings or other methods available to the owner or operator.
• Employees should be trained in the proper use of source separation equipment and program procedures. Training should enable employees to recognize what materials must be source separated, the desired quality, locations of collection containers, and how to contact program coordinators.
• Training can take place through meetings, information sessions, newsletters or pamphlets.

I refer now to excerpted recommendations from my 2013 report LITTER CONTROL IN ONTARIO: NO TIME TO WASTE.

• Include anti-littering message on Ministry of Transportation (MTO) vehicle licence renewal information inserts.
• Institute an organized system of data collection. 
• Ministry of Government Services work with Ontario Public Service regarding cigarette butt and other litter to ensure responsible waste management practices among employees at all levels of the public service. 
• Implement uniform recycling and litter prevention measures across all ministries. 
• Establish a panel to look at updating Ontario’s approach to littering to achieve better results. 
• Signal through Ministry of the Attorney General that littering charges are to be taken seriously. 
• Support those municipalities’ efforts that reinforce non-littering behaviours.
• Remove “end of life” as a term describing waste in legislation and in stewardship organization mandates so that they must take some ownership and responsibility for product litter problems.
• Include clear information about waste management and litter prohibitions in citizenship courses and pledges.
• Spearhead an assessment of Ontario’s enforcement levels and practices and begin routine enforcement of EPA Reg. 103/94 (2.1.3) on ICI sector.

A second progress report on litter was published back in 2014.

Through regulation there needs to be a higher built-in standard of action on the government agency’s part and better, enforceable accountability measures for the producers and their organizations. 
As well, the public should be told of the cost implications as industry groups pass on their costs to consumers through product price increases.

​Communication must be clear.  Targets must be set and honoured. 

Producers have largely sidestepped their obligation to educate consumers about the proper disposal of their products - tobacco, plastics, confectionery, PPE, for example.

So how well will the ministry, its agency and corporate partners communicate the facts about the Blue Box changeover, the ongoing results and who to hold accountable for fixing problems or failures and addressing complaints?

I think now specifically of wipes. These products are branded with names such as “Flushables”.  Non-recyclable, frequently littered, plastic wipes that people are wrongly flushing and creating serious maintenance issues for municipal sewer systems around the world.  They are anything but flushable. Three major Canadian companies here in Ontario have been deaf to my written and phone complaints to the CEO on down.  They peddle a generic brand of wet wipes which they label “flushable”, misleading consumers into believing that plastic wipes are safe to flush down toilets when in fact such disposal is an environmentally degrading act that is damaging to vital water and sewage treatment machinery.

​Please consult the excellent work of the MESUG (Municipal Enforcement Sewer Use Group), and build in measures in law that enable the ministry and the public to fix problems like this.
The same goes for the corporate definition of “biodegradable”. We can’t have corporations implying that if their product is strewn, it’s going to disappear on its own any time soon.  Municipal recycling systems aren’t set up to process most of these new, so-called biodegradable products like snack bag wrappers and coffee pods.

Something as simple as putting the word “litter” as a topic heading on the Ontario environment ministry’s website homepage seems impossible to achieve. I’ve tried. Such a simple request, why is it so difficult to do this one small thing? 

Given the frustration of trying to move the needle even slightly, is there even a point in my requesting standards and protocols that deal with “non-end of life” waste and hold producers accountable for getting litter prevention, recycling, education and proper disposal information to their customers? 
If not this remedy, then the government must develop an aggressive and robust alternative plan for coming to grips with Ontario’s litter problem.  With all due respect to the MECP staff behind the government’s year-one Act on Litter campaign, the need for a better program online and on the ground is clearly evident, especially when measured against global examples of concerted litter prevention programs.

I’d also like to see something built in to the legislation for controlling any mark-ups and consumer price hikes, particularly but not only in the food and grocery sectors, that come as a result of companies passing on additional costs related to meeting their corporate sustainability obligations under this legislation.
And lastly, I use this opportunity to point out that Ontario does have a PPE littering epidemic.  Increased littering overall is another unfortunate effect of COVID-19 with PPE registering as a new and prolific litter type on land and in water. Manufacturers of plastic gloves and face masks should be expected in law to have a recycling and collection program relating to these products specifically just as the wipes producers should be challenged over the “flushable” labeling.

These are my comments. Thank you for taking the time to read and consider them.  While I realize some of them may not apply to this regulation per se, I do see them as relevant to the broader discussion of waste in Ontario and what actions the province can take to improve the situation.
 
Sheila White
Litter Prevention Program

BACKGROUND: I wonder if I will receive an answer to this letter I emailed to Ontario's Minister of Environment, Conservation and Parks? I'm a big fan of writing letters to try to get action. That way I can make my frustration someone else's problem. Complaining in writing makes me feel better right away. I find relief and satisfaction knowing I've done all I can. And then I wait.  It's pretty shameful how long one can wait for a reply of any kind from government, and I have often thought it would be great if I could get paid to complain on other people's behalf.

More than a year ago I was excited to tell my readers that Ontario had finally taken a step toward addressing a long-ignored, province-wide litter problem. You'll see what I said then at the end of this post.

When I pushed the previous Liberal government to consider a review of it's approach to littering in 2012 I was mocked in some circles.  So when it looked as though Ontario under the Conservatives was about to get serious, I was jubilant.  The joy didn't last.  As I started digging, I found there was no real plan for litter action and to my mind, this is still the case. 

An #ActONlitter social media campaign was unveiled on May 12, an inaugural Day of Action on Litter, hobbled by group cleanups knocked out by COVID-19.  My former high hopes were now down the well.  I had to write the Minister responsible, MPP Jeff Yurek. (He was not the environment minister who announced Ontario's litter intentions back in March 2019.  That guy, Rod Phillips, is now the finance minister of downward spiraling deficits. You think he maybe wishes he was still minister of golf courses and campsites?)  My email Inbox surprised me just yesterday with a thank-you from Minister Yurek and his Parliamentary Assistant, a result of my pestering staff to put me on the MECP media list.  So first here's the Minister's lovely form letter, followed by my comeback.

Good morning,  

On May 12, 2020, we celebrated Ontario’s first Provincial Day of Action on Litter and I want to thank you for your participation and support that helped make it such a great success.

We saw an overwhelming amount of participation through Twitter, Instagram and other social media platforms. It was an incredible demonstration of how people across the province can come together in support of creating a cleaner Ontario for today and for future generations. 

Thank you for taking the time to recognize the Day of Action on Litter and help spread the word through your channels. On the first day alone, there were over 500 downloads of the participation guide and social assets, with a digital audience reach of nearly 2 million people. Our hashtag #actONlitter was also a top-10 trending topic on Twitter in Ontario, and #13 in Canada.

While we have postponed public and corporate cleanups until later this year to support physical distancing efforts, our hope is that these events can take place during Waste Reduction Week, from October 19 to 25, 2020. We look forward to working with you again closer to the fall in preparation for these cleanups. In the meantime, if you have any questions, please email ActONLitter@ontario.ca.

Thank you again for your support.

Jeff Yurek 
Minister of the Environment, Conservation and Parks 
Andrea Khanjin
Parliamentary Assistant to the Minister of the Environment, Conservation and Parks 
_________________

May 26, 2020

Dear Minister Yurek,

While I do sincerely appreciate your thank-you note regarding the Day of Action on Litter, I am writing to express my overall disappointment in MECP’s #ActONlitter campaign and corresponding website.

On March 10, 2019 my publication, “Litterland”, hailed your government’s decision to place a focus on litter and develop a strategy. (Please see attachment.)  I participated in your consultation process, also wrote to you directly and, subsequently, have exchanged several emails with your staff.

My goal is to see that MECP uses the opportunity it has created to put forward the best possible litter awareness program. I still have many unanswered questions about your Ministry’s approach to litter prevention.  As someone very familiar with model programs from around the world, I regret that Ontario’s falls well short of what is desirable for litter prevention education.

I am providing a critique of #ActONlitter on the assumption that you would want feedback as Ontario’s environment minister and would want your staff or the ad agency to make changes to the web page and participation guide to better reflect a focus on litter prevention.

Litter, which is ‘non-“end of life”’ waste, is not covered within your legal framework for Extended Producer Responsibility.   Along with an offering of expertise in this brief critique, based on the idea of creating a relevant and effective presence, I continue to ask that ‘LITTER’ appear as a word on the MECP home page and that it links to an upgraded litter content-rich site.  It just seems like such an obvious and easy thing to do.  May I please know if it cannot be done, why that is so?

In formulating a critique of the newly launched ontario.ca/actonlitter, I sought added input from a veteran creator of award-winning solid waste campaigns.

Critique of #ActONlitter page
- dull, fails to live up to its title “Day of Action on Litter”
- web page lacks litter facts, stats, images - Easy to find, why not include? 
- lacks cultural diversity and multilingualism
- lacks specific references to litter types: cigarettes, chewing gum, beverage containers, polystyrene, food wrappers, coffee cups, plastics, packaging, balloons, fireworks
- nor does the site speak to those who use such products directly with facts about proper disposal, hazards related to each litter type and warnings about consequences for littering.
- dog waste and spitting warrant same attention as PPE.
- good tips on reduce, reuse and correct waste sorting, but these monopolize the page. They should be a sidebar.
- images/info relating to littering should be the main event.   Provide links to other external sites too. 
- “To be launching a May 12 action day without promotion and time to organize litter pickup activities tells me this province is not serious about eliminating litter.”  This was my colleague’s comment, and I couldn’t agree more.

I would like to liaise with the staff lead responsible for organizing activities associated with future Days of Action on Litter. And may I please know what your comprehensive plan actually is for dealing with litter 365 days a year?

In closing, Minister, all I hope to gain here is your assurance that MECP will re-tool its thinking about the #ActONlitter web page and will work to make the entire program more helpful and meaningful to the cause, starting with your acknowledgment that Ontario’s environment ministry should have the word “litter” on its home page and content that matches the importance of the subject.  I’d like to use your answers in a future article and blog post.

Again, thank you for your note of appreciation.  I look forward to your reply.

Sincerely,
Sheila White
Founder, Litter Prevention Program

WITH COVID-19 ON EVERYONE'S MIND, NOW MORE THAN EVER, CLEAN IS COOL!

Back in December 2018 I spied a Toronto firefighter on my street littering a cigarette he had finished smoking at the side of his fire truck. It was a frigid early morning, but I hauled myself outside to demonstrate my displeasure over what I had seen. I stooped down and picked up the butt. I gave him a pocket ashtray that he could use the next time. "No littering," I told him, and he agreed. It was a one-minute exchange, one of those teaching moments that I'm fairly sure he will never forget.

Then I wrote to the Mayor of Toronto. I advocated for a policy that reminds smokers who work for the City of Toronto not to litter their tobacco product castoffs.

"I would like to be referred to the appropriate individual in your office, the city manager’s office or the office of Toronto Fire Services to discuss what can be done to remind City of Toronto employees who smoke that the bylaw requires proper disposal and no littering of cigarette butts, particularly not on public property or in or near city vehicles and equipment, but preferably never," said my letter to Mayor John Tory dated December 4.

"I clean my street daily in an ongoing experiment to see if I can make it and keep it litter-free.  While it is the cleanest street in Toronto, litter continues to find its way onto the street day in, day out. That speaks of broader problems of lack of education, awareness, effort and enforcement.  Could someone speak to me about this, please?"

A pretty straightforward request, I thought, as I mailed the letter and put it out of my mind.  Having run a mayor's office before I admit I have an exacting standard when it comes to communications. So I was less than impressed to receive a response four months later, an unsigned letter from Sincerely, Mayor's Administration dated April 1, 2019. Was this some kind of April Fool's joke? Did the Mayor of Toronto even see my letter? 

After thanking me for taking the time to write to the Office of the Mayor (well, actually, I wrote to John Tory), the Administration goes on to apologize for the delay in responding. "We received a high volume of correspondence from residents in recent months."

"We have forwarded your concerns to the Deputy City Manager, Chief of Fire Services and the General Manager of Solid Waste Management for their review and action. They have informed our office that they would follow up with their staff members in regards to littering, especially after you brought this incident to our attention."  (Hey, looks good on paper, nice-sounding words, but how do I know this was ever done?  Any Toronto employee who was told by city management not to litter, please contact me.)

"We have also forwarded your suggestion of having a city-wide campaign or policy to ensure city staff do not litter, to senior staff in our office for their consideration."  (That's code for saying, 'your idea is being shoved to the furthest corner of someone's messy desk and will never again see the light of day.')

There was no further follow up from the mayor's office. If they had looked out their city hall windows at the mess visitors left behind after the Toronto Raptors NBA Championship rally, maybe in hindsight they're understanding that an ongoing litter prevention campaign is a winning strategy, not a ball to dodge.

The Herzbergers of appropriately named Garden Avenue have a deep front and back yard stocked with a variety of growing and mature trees and shrubs.  Eva and Karl have lived there since New Year’s Day 1970 and their yard has provided much pleasure to them and their now-grown daughters, Susan and Karin.  The trees have provided a haven and food for birds and other local fauna, making the home a great place for viewing nature.
 
Roof-high cedars hug the house on one side in the front yard, and a Kentucky blue spruce, planted as a two-footer and just eight years ago, now stands at least fifteen feet high between street and house.  Its leader was broken early on by a neighbour child who loved to climb the tree.  With great care Karl grafted a side branch on to the damaged tip and the tree has grown strong and straight ever since.  Also in the front is a sturdy Crimson King maple with the last vestiges of yellow-brown leaves dotting the ground around and clinging to a few bare branches.  The 20-foot mountain ash rounds out the trees found in the front.  Its skyward-reaching branches form a kind of oval skeleton now that its leaves are gone.  The crop of colourful, red berries, though bitter, are welcomed by birds when all other food sources have been exhausted.
 
On the south side of the house is a “weeping” or trailing willow of shrub size.  It was carefully planted by their daughter as a Mother’s Day gift several years ago.
 
As mentioned, the backyard offers excellent bird-watching opportunities.  There are six giant black pines on the property with the familiar long-needled branches of dark green – light green in spring when new growth appears.  They provide protected branches on which the birds land.  Many, such as blue jays and cardinals, visit throughout the year, and as we looked out, “Felix” the friendly pileated woodpecker flew into one of the pines.  One winter day several years ago Eva was amazed to see what she believes was a peregrine falcon devouring the last of a small animal on the property.  Its talons were the size of the fingers of a human hand.  It shortly flew off, carrying with it a large ball of suet Eva had set out for the small birds.  Two gray squirrels live in the yard and several black squirrels are frequent visitors.  Eva has seen ring-necked pheasant often, and raccoons. A lizard and a skunk consider the yard their own.
 
Other trees found in the back yard are a sugar maple with bright red fall leaves, a large Manitoba maple whose branches have been broken many times in windstorms but still sturdily standing, 10-foot high French lilacs which give off their perfume every spring, and a European linden whose blossoms provide a pleasant woodsy fragrance when used as sachets and room fresheners.  A weathered, well-used wooden bird feeder leans at an angle near the window.  It has fed hundreds of wild birds over the years and is the source of much viewing pleasure at the Herzberger home.
 
One of the nice things about living in an area such as ours is to experience the sense of serenity a setting such as the Herzbergers’ home provides.  Year-round natural beauty and a constantly changing panorama of birds and other small creatures make it a joy to return to and visit.
 
--Mary Jo Turner, “Treading the Farquharson Forest IX”
C. D. Farquharson Community Newsletter,         November 1988
 
(Describes the Scarborough property directly behind mine - before it was destroyed one Sunday in 1994 in the absence of tree protection legislation.  It was a hugely heartbreaking event in my life.)

But back to the big news in the letter from Shoppers Drug Mart – here’s the quote that made me smile and say, “Chalk this one in my year’s accomplishments.”
 
“We appreciate your passion and concern for the environment and recycling terminology and it’s (sic) usage in society, and appreciate you taking the time to pass on your concerns and your provided documentation.  We have since forwarded your concerns onto the appropriate division for further review concerning our products,” says the letter signed with a typewritten Suzanne, an illegible signature above it.
 
I’m thinking to myself, ‘I know there’s a point in here somewhere ...’
 
“We can confirm since the draft of your letter the Life Brand Flushable wipes have since been a product we have been active in discontinuing.”
 
It doesn’t mean this major drug chain is stopping the sale of wet wipes altogether. Still, disassociating its brand name from this environmentally problematic product is a smart move that hints of sustainability savvy.

The letter from Shoppers gives me occasion to remind people to handle wipes with care by placing them in a bin or bag and never flushing them down the toilet or dropping them on the ground.
 

On January 1, 2015 an expanded ban on smoking in public places takes effect in Ontario.

The new law boots smokers from patios, parks and sports fields and is the provincial government’s much-vaunted companion to its existing Smoke Free Ontario curtailments.  For example, already in Ontario, tobacco products cannot be openly displayed or advertised and it’s against the law to smoke indoors or in vehicles carrying children.

Smoking location bans may arouse cheers from those of us sick and tired of stifling secondhand smoke choking our leisure activities from dining out to a day at the beach.  Superficially banning smoking appears to be a good thing that makes for great PR.  But Ontario’s new law has problems.  During my presentation to Toronto Board of Health early in 2014 I pleaded with politicians to develop a strategy for the cigarette butt litter the new law will generate.

Ontario’s smoking ban constitutes a licence for smokers to litter.  As well as banning smoking at entranceways the law limits the placement of ash receptacles.

In controlled environments, smokers will use ashtrays.  Pushing them to the margins, as the Smoke Free Ontario law does, smokers will flick their butts on streets, sidewalks, parking lots and lawns.   

Everywhere in the world the push is on to put a chokehold on tobacco product litter.  As a full-time litter researcher, I chronicle the campaigns from UK, AU, USA and around the globe at www.litterpreventionprogram.com .  

I do not know why Ontario refuses to look at the issue, but my point here is that as of tomorrow under the new Smoke Free Ontario legislation, guaranteed, a prolific butt litter problem in this province is about to get worse.

A new study from a Japanese Univeristy (Kyoto) took a close look at the 140+ municipal smoking bans that do exist and found, surprisingly, that health was not the driving reason for bans.  Instead these moves to ban smoking were made to deter smokers from littering in those public places after indoor bans sent the smokers out of doors. 

In Japan they have a culture of respecting cleanliness and tidiness.  There you find enforcement of littering laws.  Litter education is mandatory in Grade 4.  

Ontario officials like to say that littering is a municipal official not requiring higher-level government involvement.  Interesting then that municipal enforcement officers are not empowered to lay charges under the Smoke Free Ontario Act.

When I first heard this at a City of Toronto working group meeting on litter I was stunned.  Under the new law municipal authorities are not the enforcers of the patio ban, the beach ban, the park ban, the ban on cigarette sales on campuses.  Municipal bylaw inspectors are impotent: only provincial health officers have the power to tag offenders.

This is Ontario’s stand:  You usher in a ban.  To start with, you have no enforcement plans, no plan for a cigarette butt litter awareness campaign. You don’t allow ash receptacles where they are needed.  In fact you tie municipal hands. And lastly, you give no funding or attention whatsoever to quelling the undesirable habit of littering, cigarettes being the most prolific on a long list of garbage-on-the-ground items.  Is this not crazy?  

Sixty-five per cent of smokers litter their butts, it is estimated.  There are all kinds of nasty chemicals in those cigarette and cigar ends, and the e-cigarette waste is a whole other noxious stream in the making. Research provides strong environmental arguments for taking action. 

If smokers can’t quit smoking at least they can quit littering.

No self-respecting province should be without a strategy for dealing with cigarette butts, which now can be recycled if captured not strewn.

The introduction of new Smoke Free Ontario clampdowns is an ideal time to get our butts moving on a litter prevention strategy.

Sometimes a kid’s first introduction to smoking comes with the discovery of a littered cigarette butt.