1.0 General Introduction
The drafting team composed of 4 persons from Uganda and 2 from Norway participated in a work visit to South Africa for the development of Guidelines for Hazardous Waste landfills. The participants were welcomed by Ms Stella Ongoma and the administration staff. Present in the meeting was Mr. Johan of Environserv who was an important resource person from the waste management Industry.
Dr. Richard Nyanzi facilitated the meeting on Monday the 16th of May 2016, by introducing the South African Waste Classification and Management Regulations. On Tuesday and Wednesday, the team visited Enviroserv and the Africa Institute for the Rotterdam, Basel and Stockholm Conventions. On Friday the team visited the Department of Environmental Affairs. The team also perused and re-drafted some parts of the zero draft of the Guidelines for Hazardous Waste Landfills developed by Nancy Awori on behalf of the team, to provide a basis for initial discussions.
2.0 Discussion on the South African Waste Classification and Management Regulations.
The National Environment Management Act of South Africa was introduced as providing the framework for hazardous waste management. The Waste Regulations were also presented, as was an outline of South African Standard 10234 designed on the Globally Harmonised System for chemicals. Standards for transport, storage and landfilling of waste were also referred to.
The obligation of generators of waste and the waste managers to classify and track the movement of waste was emphasized, as was the importance of laboratory analysis.
The generator of hazardous waste is required by law to maintain a material safety data sheet and a waste manifest. The generator of hazardous waste is also required by law to attach a unique identification number to the waste manifest for proper identification of the waste. This requirement applies to each stream of waste once that waste is re-classified following its change in composition.
The shift from Minimum Requirements for waste handling to the new legal regime was required to be completed by August 2016. However, some waste generators had not even started the first important step of classifying the waste.
There was concern about the 180 days within which waste should be disposed off, as this can be a subject of abuse.
The importance of allowing Industry to develop good practice was noted; and Mr. Johan highlighted the role of Enviroserv in this regard.
It was noted also that in South Africa the economy is industry-led. Hence, most times, the regulator asks industry to come up with a plan to help regulate a particular sector of industry. Then the regulator follows through with refining the plan and operationalising it.
Key observations included;
- The real generators of hazardous waste, including potential generators of similar waste should be identified to enable proper management of that waste.
- It is important to put in place systems for the management of hazardous waste and to test those systems for effectiveness. Commitment to enforcing that system is key.
- The waste hierarchy is important before recourse to landfilling as one method of hazardous waste disposal.
- Where hazardous waste is considered for land filling, it is important that the planning and design should be well done to ensure that the operation of the landfill does not cause contamination of ground water and a host of other hazards.
- Classification of waste for collection and disposal is important.
- Hazardous waste needs to be disposed off in a hazardous waste facility, not any other landfill.
- Separate nuclear waste from naturally occurring radioactive materials like mining waste. In South Africa, mining waste has hitherto been handled by the Department of Energy Resources. But lately, there has been a discussion to move this waste into the realm of Department of Environment Affairs.
- 2 levels of approvals do exist for radioactive waste in South Africa i.e. from the regulator of nuclear waste and then from the Department of Environment Affairs.
- Management of biodegradable waste may include composting and use of that waste for energy generation. However, studies should be undertaken to ensure that this is a viable undertaking i.e. that there are recipients of this products, and that the associated costs are manageable. For instance, power generation from waste is usually more expensive than electricity from hydro power. Also, where people usually use fertilizers, they may not take well to use of manure.
- It could be useful to prioritise waste streams for regulation, and to identify regional centres for the management of hazardous waste because of the high costs associated with practices such as landfilling.
- Waste Manifest System
- Each waste generator of hazardous waste is given a unique registration number to help track the movement of that waste which the waste collector records. This helps the government know how much hazardous waste is being generated and reported.
- The waste handler may analyse the waste from the waste generator and disagree with a “non-hazardous” characterisation of the waste and require proper categorization of the waste.
- Government can enforce proper waste categorization by use of environmental inspection and audit.
- Include a provision in the law for a generator of waste to prove that the waste is non-hazardous and another to monitor municipal waste landfills to ensure that no hazardous waste is disposed off there.
- The waste handler reports the waste collected monthly.
- There is need for a weigh bridge to weigh amount of waste entering a municipal landfill.
- Requirement for a waste manifest does not apply to a waste generator who also manages his own waste. Instead, the waste manager will be bound by other applicable laws, e.g. if they burn used oil – then the air quality regulations will apply.
- Electronic logging of the Waste Manifest with the Department of Environment Affairs was encouraged in order to obtain real time data; however, the associated cost of maintaining the electronic system is quite high.
- The viability of having both a material safety data sheet and a Waste Manifest for the same waste should be looked into; and the length of the documents should be manageable – probably not the 4-5 pages like the South African ones.
- Coordination among institutions in-country is imperative, especially where resources are scarce and competencies such as in laboratory analysis are lacking.
- Technical committees within the regulatory institutions should be empowered to take decisions to be effective in hazardous waste management.
The team commenced drafting the guidelines for landfills for hazardous waste. This was based on the raw draft developed by Nancy Awori as the working draft. The team drew from the experience of South Africa, Norway and the European Union.
As general guidelines it was noted that the guidelines should-
- be slim.
- have an index
- have a clear purpose and intention
- include tables and appendices
- be more like a handbook – easy to use and apply
The guidelines should also include access to environmental information and involvement of the public in the Regulations for Waste Management – during siting, construction, re-modelling of a hazardous waste facility or when the waste handler is planning something around the facility (see the Seveso III Directive on Major Accidents).
The team worked on developing the guidelines and assigned tasks to the team members to enable the completion of the first draft.