Irish green credentials fail on pharmaceutical waste exports

Foreign investment in Ireland's pharmaceutical sector has gone from strength to strength in 2019. With major new multi-billion-dollar investment projects lined-up and the expansion of existing manufacturing facilities rolling in, the IDA development agency has reason to be pleased, as well as confident for the outlook in 2020. But there is an environmental cost to this level of inward investment, which pharmaceutical companies and Irish policymakers are increasingly mindful of. Topping the policy agenda is industry's requirement for a new largescale public investment program to curtail the sector's cost of doing business in Ireland in the context of having to export hazardous waste.

Public investment to improve pharma waste systems in Ireland are increasingly seen as a key component in winning foreign direct investment from the pharmaceutical sector. Takeda (Japan)'s chief executive Christophe Weber recently raised the profile of waste treatment spending on behalf of the pharmaceutical industry when he claimed that the creation of an enhanced domestic capability could secure "big competitive advantages" for Ireland. Doing more waste management locally, rather than relying on shipping waste overseas to countries that are exposed to increased sensitivity over contamination, offers a potential win-win opportunity for the pharma-sector and the green-lobby.

More efficient production methods in the Irish pharma sector have led to a decrease in waste material treated on the site where it is generated. Analysis of data published by the Environmental Protection Agency (EPA) reveals that there was a 5.9% annual reduction in on-site treatment at licensed EPA industrial facilities to 34,114 tons of hazardous waste in 2017. This covers all industrial sectors, not just pharmaceutical manufactures and does not include solvent-based chemistry in the biopharma industry which can be reclaimed on-site and regenerated to re-enter the industrial process.

Domestic hazardous waste treatment facilities handled a further 86,909 tons, up 24.5% year-on-year. However, despite these positive indicators, the amount of industrial waste Ireland exports abroad continues to rise at double-digit rates. The EPA notes that in 2017 total exports of hazardous waste across all industry sectors - including chemicals and medical waste which Ireland does not have the facilities to fully dispose of - amounted to 213,089 tons. This equates to an annual increase of 14.6% and followed growth of 11.9% and 17.7% in previous years. About 48.8% of hazardous waste produced in Ireland is therefore exported abroad for treatment. The pharma sector is by no means the only manufacturing industry to contribute to this controversial statistic. But pharma has a critical mass in the Irish economy, and the EPA data paints a picture of rapidly increasing waste generation and export.

Export costs are borne directly by manufactures in Ireland. This bottom-line encourages industry leaders to speak out more forcefully in favor of the government prioritizing self-sufficiency nationally as a guiding policy principle, not only on the legitimate grounds that this is the most preferable course of action from an environmental perspective but also from manufacturer's economic point of view.

Another rationale for increasing Ireland's level of capacity for self-sufficiency with regard to the treatment and management of hazardous waste generated by pharmaceutical industry is that the United Kingdom is by far the largest recipient of pharmaceutical sector waste exported from Ireland; a total of 30.7% of overall hazardous waste is exported to the UK mainland and 6.5% to UK region of Northern Ireland. The Netherlands (20.8%), Germany (18.3%) and Belgium (13.7%) absorb about 52.8% combined. This reliance on Ireland's nearest neighbor for incineration and disposal facilities may pose a long-term problem in the context of the UKs impending departure from the European Union (EU). Substantial policy attention has been paid to the negative impact on trade flow of finished medicine products and active pharmaceutical ingredients back-and-forth across the Irish and UK borders. Less consideration has been given to the risk that trade disruption caused by a disorderly UK exit from the EU could have on the export of pharma industry waste material for treatment outside Ireland.

To a certain extent Ireland is an outlier in an EU context when it comes to managing pharmaceutical industry waste. On the one hand, it produces less hazardous waste per capita overall than the EU average. At the same time, the country lacks the infrastructure to fully treat hazardous waste and is forced to export a disproportionately large share to other EU countries and the UK. This trend is not just a problem of under-investment and unfulfilled policy goals by consecutive governments. It also reflects Ireland's long history of local political and planning opposition to the construction of waste management capacities (especially incineration facilities), a large number of which would be necessary if Ireland intended to manage all pharmaceutical waste in-country. The preference for shipping the bulk of pharmaceutical waste exports overseas does appear to be waning amid the growing importance of "green" issues in the public consciousness. However, Ireland has a poor track record of delivering largescale infrastructure projects. The process of securing planning permission is often notoriously lengthy and local opposition to controversial infrastructure has derailed entirely or added significantly to cost of construction. This is still a feature of the Irish landscape and is certain to hinder Takeda and the wider pharmaceutical industry's attempts to persuade government ministers to pile new investment into this policy area. Given the government's current low-ebb politically and larger strategic problems on the horizon, such as the UK's departure from the EU bloc, neither the current minority Fine Gael administration nor opposition political parties are likely to take up the policy gauntlet of better pharmaceutical waste management and the reduction of waste exports at the next 2021 election.

Posted 02 August 2019 by Eoin Ryan, Senior Analyst