Waste Classification

The Department of Environmental Affairs (DEA) has developed and piloted a national system for the collection of data on waste generation and management in the country, which will be gazetted by early 2012. Raj Lochan explains the implications and requirements for local businesses.
The South African Waste Information System (SAWIS) is currently being refined through the DEA’s development of a revised waste classification and management system that will be formalised through the National Waste Information Regulations. The main objective of waste data collection is to allow for adequate waste management planning and prioritisation by the DEA, and to enable the department to report on the success of national waste policy and waste management initiatives aimed at moving waste up the hierarchy from land filling to re-use, recycling, recovery or treatment.
SAWIS comprises a central registry and a data capture facility. All waste management facilities as well as hazardous waste generators (generating more than 20 kg/day) are required to register on the system. Reporting to the system would, however, be required from waste management facilities only, i.e. reporting from the point of final management where waste is re-used, recycled, recovered, treated or disposed, which could be the generator in the case of on-site waste management activity. Waste generators’ and transporters’ responsibility in terms of reporting would be to ensure the flow of information to the waste manager through a hazardous waste manifest system, which would be formalised through National Waste Classification and Management Regulations that was gazetted at the end of 2011. The validity of waste data on types of hazardous waste in the manifest will be the responsibility of the waste generator.
Hazardous waste generators that generate more than 20 kg/day will be required to register on the SAWIS. The generators’ specific Standard Industry Code (SIC) would be captured upon registration. Categorising waste generators in terms of the SIC would enable DEA to efficiently report to national statistics (StatsSA), and is in line with industry sustainability reporting parameters.
Part four of the categorisation system will indicate what the final fate of the waste is, i.e. which management option or technique was implemented to deal with the specific waste stream. Three different types of codes have been developed to reflect broad categories of management options for both general and hazardous waste as follows:
R-code: Waste re-use, recycling and recovery options
ê T-code: Waste treatment technologies
ê D-code: Waste disposal techniques.
Implementation, reporting
The categorisation system will be enforced through the National Waste Information Regulations, and the categories (parts one to five) would be included as an annex to the regulations. It will be mandatory for waste managers (disposal, treatment and recycling facilities) to report on these categories to the system. Diversion of waste from landfill will be tracked by calculating recycling and treatment rates, and information will be gathered of the types of waste generated and treated per industry sector.
Currently, reporting to the SAWIS is required only up to level two for waste types (i.e. major waste types) and quantities generated are aggregated per municipal regions. However, once the waste information regulations have been gazetted, reporting will be required to include level three wastes (specific waste types), as well as the quantities from the specific generators of the waste (who would only be required to register on the SAWIS, not report). Waste managers will be required to report to the SAWIS, and will identify which management option/s are implemented at their facilities, i.e. a waste management facility would register individual plants (e.g. landfill and/or treatment plant
and/or incinerator etc.) that are operating at the same site.
Provincial waste information systems would feed data into the national SAWIS. Where provincial systems exist, the generator would only register with the province, and waste managers would report to the province only, i.e. one point of registration and reporting. The province would be responsible for relaying information to the national system.
Get ready for the Waste Act
The Waste Act places certain responsibilities and requirements on generators, transporters (collectors) and processors (recyclers) of hazardous waste.
ê Every holder of a waste that has been classified as hazardous must be in possession of a waste manifest document containing the relevant information specified in the regulations for the waste
ê All generators of waste classified as hazardous must complete a waste manifest document containing information for each consignment of waste transported to a waste manager
ê Waste transporters may not accept waste classified as hazardous for transport unless the waste manifest document accompanies the waste.

The Waste Manifest System

Information to be supplied by the waste generator:
• Unique consignment identification number (bar code)
• SAWIS Registration number in terms of the National Waste Information Regulations, 2010 (if applicable)
• Generator’s contact details (contact person, physical and postal address, phone, fax, email)
• Physical address of the site where the waste was generated (if different);
• Emergency contact number
• Origin/source of the waste
• Classification of the waste
• Physical characteristic / consistency of the waste (liquid, solid, sludge)
• Quantity of waste in tons
• Packaging (bulk, small containers, tank)
• Transport type (tanker, truck, container)
• Special handling instructions
• Date of collection / dispatch
• Intended receiver (waste manager)
• Declaration (content of the consignment is fully and accurately described, classified, packed, marked and labelled, and in all respects in proper condition for transportation in accordance with the applicable laws and regulations).
Information to be supplied by the waste transporter:
• Name of transporter
• Address of transporter
• Vehicle registration number
• Transport permit number
• Declaration acknowledging receipt of the waste.

Information to be supplied by the waste manager:

• Name, address and contact details
• Receiving waste management facility name, address and contact details (where different)
• Waste management facility licence number
• Date of receipt
• Quantity of waste
• Type of waste management applied (re-use, recycling, recovery, treatment, disposal)
• Any discrepancies in information between the different holders of the waste (related to waste quantity, type, classification, physical and chemical properties)
• Waste management reporting description and code in terms of the National Waste Information Regulations 2010
• Details on any waste diverted to another waste management facility and details of the facility
• Certification and declaration of receipt and final management of the waste.

The penalties of non-compliance

Strict penalties are to be put in place for anyone who fails to comply with the provisions of the regulations. These include either imprisonment (not exceeding 15 years) or an appropriate fine, or possibly even both.
“The Rose Foundation and NORA-SA will be conducting extensive training for all our members and collectors to educate them on the hazardous waste manifest and the waste classification system so that they are all fully up to speed with what is required,” explains Rose Foundation CEO Raj Lochan
“We are working closely with government to ensure that the used oil industry stakeholders remain compliant at all stages.”

Redisa Update

The following is a press release issued by the Department of Environmental Affairs on behalf of Honourable Minister Edna Molewa:
The Department of Environmental Affairs is constitutionally mandated to ensure the protection of the environment and conservation of natural resources, balanced with sustainable development and equitable distribution of the benefits derived from these processes.
The recent developments in the waste tyre management space are a reflection of the department’s commitment to our constitutional imperatives, as well as our commitment to ensuring fruitful engagement with industry and affected stakeholders.
In our quest for an inclusive waste tyre management regime, Minister Collins Chabane, with my full support and acting on my behalf as the Minister of Water and Environmental Affairs, withdrew the approval for the Integrated Industry Waste Tyre Management Plan (IIWTMP) of the Recycling and Economic Development Initiative of SA (Redisa). The Redisa plan was approved by notice in the Government Gazette Notice (No 983 published in Gazette No 34796) published on November 28.
The withdrawal of the plan will afford the department the opportunity to attend to procedural requirements stipulated in the tyre regulations. Thus the withdrawal is a reflection of the government’s willingness and commitment to due process as well as engagement with all stakeholders. The withdrawal of the plan does not in any way display less commitment by the government to SA’s waste tyre problem.
The government remains committed to dealing with the millions of waste tyres that lead to pollution. In fact we are preparing ourselves for a rerun of the public participation process in respect of the Redisa plan. We anticipate there will be constructive and valuable input into the IIWTMP. Why does SA need a waste tyre management plan? Over 200 000 tons of tyres become waste tyres in SA annually. This figure will increase every year by 9.5 percent.
If not managed properly, waste tyre stockpiles provide breeding grounds for mosquitoes. Tyre stockpiles can easily ignite, so this presents a major fire hazard. There is significant air pollution arising from burning tyres as people seek the wire in tyres, which is currently fetching a better price than tyres.
We also face the problem of depletion of airspace fast in landfill sites as tyres are bulky and do not biodegrade. This is of particular concern given the fact that existing landfill sites in municipalities are fast reaching their end (the City of Joburg is left with a couple of years on its landfill sites).
Land availability for the establishment of new sites is not easy, as land is contested for a wide range of other uses, which take precedence, for example housing, industry and agriculture.
All of this highlights the need for an IIWTMP. SA requires a plan, which engages all the relevant stakeholders and speaks to the empowerment of communities and small to medium enterprises in the tyre recycling space.
The Waste Act has a range of tools available to the government for managing various waste streams. These tools fall into two main categories: command and control, and co-regulatory tools.
In the case of waste tyres, the government opted not to use the command and control instruments where, in the main, the government would dictate to industry exactly how the waste stream should be managed. We have chosen the co-regulatory approach, and work with and rely on industry in crafting a plan to manage waste tyres.
All this is based on a simple assumption that the tyre industry is responsible enough to collaborate with the government and find solutions to environmental problems.
Even though the development and implementation of a waste tyre management plan is still the way the government wishes to address the waste tyre problem, command and control tools are available to us for use in dealing with waste tyres, and these may be used if necessary.
We aim to use all legislative instruments at our disposal to address problems we have had for decades with our waste by instituting mechanisms of waste avoidance, minimisation, re-use, recycling, recovery, collection, transportation and storage, as well as environmentally sound treatment and disposal of problematic waste streams.
The government is committed to ensuring that South Africans take as little waste as possible to landfill sites. Thus the withdrawal of the Redisa plan’s approval is not in any way a reflection of inadequacies in the plan. The withdrawal has nothing to do with the merits of the plan, but instead is intended for the department to ensure that all the requisite procedures are followed to the letter, as prescribed in the tyre regulations.
There are allegations about creating a monopoly with the approval of the Redisa plan. I considered two plans before approving the Redisa plan last year, and I approved the Redisa plan based on its merits. I rejected the SA Tyre Recycling Process (SATRP) plan as it did not meet the requirements of the regulations in respect of the contents of a plan. Last week Minister Chabane issued a letter to the SATRP, granting their request to resubmit their plan.
The SATRP plan will go through the same process of public consultation as the Redisa plan, and all South Africans will have an opportunity to interrogate it. If it meets the standard of the regulations, it should be approved; if not, it won’t.
The waste tyre regulations require the tyre plan to pay specific attention to social responsibility, inclusion of previously disadvantaged individuals, job creation, training and development.
Notwithstanding the importance of the other requirements in terms of the regulations, these requirements are very important aspects in view of our socio-economic status and past as a country, and should not be taken lightly.
The tyre sector already has over 5 000 people (largely previously disadvantaged) operating on an informal basis; these individuals must be incorporated.
We all have a responsibility to act in line with the programme of action developed by this government. Thus I will ensure that the department, through its policy initiatives, programmes and plans, implements the broader mandate of this administration.
We will always support ways of contributing towards sustainable livelihoods. We will actively pursue any environmental management solution that creates jobs. These issues are best addressed when the decision-making structures are free from the influence of industry interests.
Thus the department wishes to see a very clear separation between industry stakeholders making input into and provision for the waste tyre management plan, and a governing body that must implement the plan and be accountable for the requirements that the department puts in place.
These are critical aspects in view of SA’s socio-economic status and this department’s constitutional mandate to strike a balance between economic, social and environmental development.
I have been taking note of the allegations in newspaper articles against the department, and my office and I will act accordingly, within the ambit of the constitution, to deal with these.
The department therefore welcomes and looks forward to productive engagements with all stakeholders in dealing with the management of waste tyres.