1.1 Introduction

1.1(1)
Every archaeologist knows that one of the best ways to study historical societies is to examine the layers of accumulated debris in middens, the equivalent of today’s landfills. Accumulated waste deposits tell a fascinating story about what societies consume, their levels of affluence and production technology, and very importantly, how they manage their waste. Indeed, through the history of human civilisation, some societies at the peak of their development have collapsed due to inadequate management of their accumulating waste burden, and the resultant proliferation of disease, environmental degradation and ultimate impact on their ability to produce and reproduce effectively.

1.1(2)
This is an apt reminder of the challenges we face today, with a rapidly growing, urbanising and consumerist population in a world in which the ability of the environment to absorb solid and liquid waste and emissions is finite. The waste that we end up disposing represents a liability that we pass on to future generations, and the manner in which we manage and dispose of our waste tells a crucial story about our level of response to these constraints, and will be a key determinant of the nature of our future society.

1.1(3)
Through our commitment to sustainable development, South Africa aims to balance the broader economic and social challenges of a developing but still unequal society with protection of our environmental resources. For this reason we subscribe to the vision of a prosperous and equitable society living in harmony with our natural resources, which means eliminating the unnecessary use of raw materials, and ensuring sustainable product design, resource efficiency and waste prevention. It means re-using products where possible; and recovering value from products when they reach the end of their lives through recycling, composting or energy recovery. While the elimination of waste in its entirety may not be feasible, through the systematic application of the waste hierarchy it is possible to reach a point within the next few decades where recovery, reuse and recycling and alternative disposal technologies overtake landfills are preferred means of disposal.

1.1(4)
The challenge of waste management affects every person and institution in society. The measures set out in this strategy cannot be undertaken without a collective approach to waste challenges, and the involvement of a broad range of stakeholders in their implementation. This National Waste Management Strategy (NWMS) seeks to establish a common platform for action between stakeholders in order to systematically improve waste management in South Africa.

1.1(5)
The NWMS is a legislative requirement of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), here after referred to as the “Waste Act”. The Act requires that it is reviewed at least every five years, and the focus of this strategy is therefore on the strategy’s waste management measures and actions that need to be taken within the next five years.

1.1(6)
The NWMS is composed of five main sections, each containing a number of chapters:

• Section One describes the methodology followed in developing the NWMS, and establishes the socio-economic and legislative context within which the NWMS must be located.
• Section Two sets out the overall goals and approach to implementing the waste hierarchy, and the strategies to be followed in addressing each stage of the waste hierarchy.
• Section Three describes each of the regulatory, economic and fiscal instruments that will be used to give effect to the strategy set out in Section Two.
• Section Four responds to the challenges we face in relation to specific categories of waste, and describes how the different instruments described in Section Three in relation to each waste category will be applied.
• Section Five deals with the various mechanisms for implementing the NWMS, and sets out the roles, responsibilities, coordination and review mechanisms.

1.1(7)
An action plan, which sets out the different interventions by the three spheres of government in order to give effect to the NWMS, is contained in Appendix Two.

1.2 Approach and methodology

1.2(1)
The development of the NWMS has been approached according to the provisions of Section 72 and Section 73 of the Waste Act, which require a consultative process, including public participation and consultation with relevant national and provincial departments.  

1.2(2)
The development of the strategy has followed a four phase consultative process presented in the table below, with stakeholder consultations incorporated into each phase of the development of the NWMS:

Table 1: Phases for developing the NWMS

PHASE	ACTIVITIES AND OUTPUTS
INCEPTION PHASE March - June 2009	Review of previous policies & drafting of NWMS framework. Establishment of Project Steering Committee. Launch of NWMS website as part of online consultation process. Key outputs: Stakeholder Consultation Report & NWMS Framework
SITUATION & BASELINE STUDIES June - September 2009	Research conducted on key identified topics. Consultation on baseline research reports. Synthesis paper summarising key issues arising out of the baseline research reports and consultation process, and the development of a strategic issue paper. Key outputs: Research Papers, Research Conference Report & Strategic Issues paper
STRATEGY FORMULATION September - December 2009	Consultation on strategic issues paper. Review of stakeholder comments, engagement with PSC and key government agencies. Preparation of first draft of the NWMS. Key outputs: agreement on key strategic issues, first draft of NWMS
CONSULTATION & FINALISATION January 2010 - June 2010	Publication of draft NWMS. Extensive consultations on the NWMS with the three spheres of government, industry and civil society. Based on stakeholder inputs, finalisation of the NWMS. Submission of NWMS to Cabinet for approval. Key outputs: Cabinet approval of NWMS

1.2(3)
An innovative feature of the consultation process has been the establishment of a website (www.deat.gov.za/nwms/) to facilitate public participation and comments on the key policy documents produced as part of the process of drafting the NWMS.

1.2(4)
The considerable body of environmental legislation and policy developed since 1994 has informed the preparation of the NWMS, including the 1999 NWMS and the 2000 White Paper on Integrated Pollution and Waste Management The NWMS draws on the policy foundation and experience with implementing the 1999 NWMS, published by the Department of Environmental Affairs and Tourism (DEAT) and the Department of Water Affairs and Forestry (DWAF) in 1999.  This 1999 NWMS set out an integrated approach to waste management, cradle-to-grave management of waste products, and the waste hierarchy approach. As part of the process of compiling the NWMS, the success in implementing the 1999 NWMS was reviewed. Notable achievements include establishing a waste information system, waste minimization and recycling, and healthcare risk waste management. There has been uneven and delayed implementation of the 1999 NWMS, and some aspects of it have not been implemented at all, largely due to institutional and regulatory constraints. Voluntary reporting has limited the effectiveness of the Waste Information System.

1.2(5)
However, as a statutory instrument in terms of the Waste Act, the new NWMS differs substantively from the 1999 NWMS, which lacked legal status and thus enforceability.

1.2(6)
The NWMS deals with general, commercial and industrial waste streams, including hazardous waste, healthcare risk waste and waste streams from agriculture (obsolete pesticide stockpiles), power generation and mining (excluding residue deposits and stockpiles). The NWMS excludes consideration of nuclear waste, which is the subject of separate policy processes under the Department of Mineral Resources (DMR) and the disposal of animal carcasses which is regulated under the Animal Health Act, 2002. While pollution from waste products clearly is an important issue, the strategy does not deal with pollution per se, but only deals with the related fields of environmental impact management in relation to waste and remediation of contaminated lands. The NWMS also excludes consideration of air quality management, waste water and industrial effluent management, which are the subject of detailed policy and regulatory processes in their own right. The NWMS only deals with water quality issues to the extent that they are relevant to the regulatory framework for waste management. Lastly, it excludes residue deposits and stockpiles as these are regulated by the Mineral Resources and Petroleum Development Act, 2002.

1.2(7)
In the development of the NWMS, DEA has endeavoured to ensure that the strategy is aligned with the existing institutional arrangements, and intergovernmental relations and fiscal systems of government. The NWMS seeks to mainstream waste management priorities and measures within government planning and reporting systems, and ensure that it is accorded the appropriate level of priority. At the same time, DEA is cognisant of the real capacity constraints faced by many government agencies, particularly municipalities.

1.2(8)
The NWMS strives to promote the flexible deployment of appropriate instruments to address specific waste management challenges, in which command and control regulatory approaches are complemented by economic incentives, voluntary initiatives and self regulation for well performing industries. At same time, more interventionist measures will be invoked where lack of co-operation exists and an integrated approach to persistent waste problems require it.

1.2(9)
The Waste Act indicates that the strategy must be reviewed by the Minister at intervals of not more than five years. While the time period to be covered by the strategy is not specified, the bulk of the strategy’s provisions will relate to the five year period prior to the next review of the strategy.

 

1.3 Constitutional and legal framework

1.3(1) The National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) fundamentally reforms the law regulating waste management, and for the first time provides a coherent and integrated legislative framework addressing all the steps in the waste hierarchy. In doing so it builds on the considerable body of environmental legislation which has developed since 1994. The Constitution of South Africa, 1996 (Act 108 of 1996) (the Constitution) provides the foundation for environmental regulation and policy in South Africa. The right to environmental protection and to live in an environment that is not harmful to health or well-being is set out in the Bill of Rights (section 24 of Chapter 2). This fundamental right underpins environmental policy (such as the White Papers on Environmental Management and Integrated Pollution and Waste Management) and law (principally the National Water Act; and National Environmental Management Act (NEMA)). NEMA states that:

“the State must respect, protect, promote and fulfill the social, economic and environmental rights of everyone and strive to meet the basic needs of previously disadvantaged communities; inequality in the distribution of wealth and resources, and the resultant poverty, are among the important causes as well as the results of environmentally harmful practices.”

1.3(2)
The White Paper on Environmental Management established the concept of the waste hierarchy in South African environmental policy, and the concept was subsequently given legal expression in NEMA. The waste hierarchy is a systematic and hierarchical approach to integrated waste management, addressing in turn waste avoidance, reduction, re-use, recycling, recovery, treatment safe and disposal of waste as a last resort.

1.3(3)
NEMA introduced a number of additional guiding principles into South African environmental legislation, including the life-cycle approach to waste management, producer responsibility, the precautionary principle and the polluter pays principle. NEMA also places a duty of care on any person who causes significant pollution or degradation of the environment, requiring them to institute measures to prevent pollution from occurring, or to minimise and rectify the pollution or degradation where it cannot reasonably be avoided. The Waste Act echoes the duty of care provision by obliging holders of waste to take reasonable measures to implement the waste hierarchy whilst protecting the environment and public health.

1.3(4)
Chapter 5 of NEMA promotes the application of appropriate environmental management tools in order to ensure the integrated environmental management of activities, and provides instruments for co-ordination and co-operation for integrated waste management.

1.3(5)
The Waste Act forms an integral part of this overarching legal and policy framework, providing specifically for the management of the waste sector and regulation of waste management activities. The Waste Act is based on the Constitutional assignment of legislative and executive powers between the three spheres of government. The Constitution assigns concurrent legislative competence to national and provincial government in respect of the environment and pollution control (section 146 of the Constitution) and exclusive provincial legislative competence to the local government matters of cleansing and refuse removal, refuse dumps and solid waste disposal. The Constitution allows national legislation to provide for national norms and standards relating to these matters where national uniformity is required to deal effectively with an issue.

1.3(6)
Accordingly, the development of norms and standards is the foundation of the regulatory system established in terms of the Waste Act. National government is obliged by the Waste Act to develop norms and standards on key regulatory matters, while it may develop additional norms and standards on certain ancillary matters. Provinces and municipalities are also permitted to develop standards provided they are not in conflict with national standards. Norms and standards developed in terms of the Waste Act also need to take cognisance of some important sectoral legislation, including the National Environmental Management: Air Quality Act (No. 39 of 2004) and the Health Act, 2004 (No. 61 of 2003).

1.3(7)
The Waste Act establishes cooperative governance mechanisms for dealing with matters such as waste planning, appointment of waste management officers and performance reporting. National and provincial government departments are also constitutionally obliged to support municipalities in the execution of their functions.

1.3(8)
Due to the significance of municipal waste services, the Waste Act needs to be read in conjunction with the body of legislation regulating local government, including the Municipal Finance Management Act, 2003, and the Municipal Systems Act, 2000, which create the overall framework for planning, budgeting, service delivery and reporting at local government level. There are some important overlapping provisions regarding waste services. For example, section 94(e)(ii) of the Municipal Systems Act allows the Minister to make regulations or issue guidelines for incentives and penalties to encourage the recycling of waste. In terms of section 74(1)(h) of the Municipal Systems Act, a municipal council must adopt and implement a policy on the levying of fees for municipal services provided by the municipality itself or by way of service delivery agreements. The policy encourages the economical, efficient and effective use of resources, the recycling of waste and other appropriate environmental objectives. Municipalities may also develop their own by-laws to provide for a municipal waste removal system in the municipal area.

1.3(9)
The Waste Act also needs to be read in conjunction with other sectoral legislation. For example, the Minerals and Petroleum Development Resources Act, 2002 section 39(3)(iii) states that Environmental Management Plans must comply with any prescribed waste standard or management standards or practices. The application of the Waste Act is also limited by reference to other sectoral legislation – it does not apply to: radioactive waste¹ , residue deposits and residue stockpiles² ; the disposal of explosives³ ; nor the disposal of animal carcasses⁴ , which are all regulated by their own sectoral legislation.

1.3(10)
Subsequent amendments to and regulations⁵ issued in terms of NEMA have provided a detailed regulatory framework for the performance of Environmental Impact Assessments; and the systems and procedures for considering EIAs are closely aligned with the provisions for licensing of waste management activities. Environmental Management Inspectors (EMIs) are also designated and appointed in terms of NEMA, and these provisions form the backbone of the compliance and enforcement system that is required to support implementation of the Waste Act. The designation of Waste Management Officers (WMOs) is stipulated for in the Waste Act where an officer can be designated at a national, provincial and municipal level and the officer is responsible for coordinating matters pertaining to waste management in the various tiers of government.

1.3(11)
The Waste Act introduced a definition of waste, which has major implications for those activities that have traditionally not been treated or regarded as waste. Importantly for industry, the waste products and activities that fall outside the definition of waste are able to avoid the provisions of the Act. The definition of waste, as per the Waste Act, is as follows:

“waste” means any substance, whether or not that substance can be reduced, re-used, recycled and recovered –

1. that is surplus, unwanted, rejected, discarded, abandoned or disposed of;
2. which the generator has no further use of for the purposes of production;
3. that must be treated or disposed of; or
4. that is identified as a waste by the Minister by notice in the Gazette, and includes waste generated by the mining, medical or other sector; but –
   
   1. a by-product is not considered waste; and
   2. any portion of waste, once re-used, recycled and recovered, ceases to be waste;

1.3(12)
Given the exclusion of by-products, their definition in terms of the Waste Act is also important:

‘‘by-product’’ means a substance that is produced as part of a process that is primarily intended to produce another substance or product and that has the characteristics of an equivalent virgin product or material;

In order to clarify some of the definitional issues, a technical guideline has been developed and gazetted by DEA as a basis for interpreting and applying the definition by both government and industry.

Footnotes:

¹Radioactive Waste regulated by the: Hazardous Substances Act, 1973 (Act No. 15 of 1973), the National Nuclear Regulator Act, 1999 (Act No. 47 of 1999), and the Nuclear Energy Act, 1999 (Act No. 46 of 1999)

²Residue deposits and stockpiles regulated by: the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002.)

³Disposal of explosives regulated by: the Explosives Act, 2003 (Act No.15 of 2003)

⁴Disposal of animal carcasses regulated by: the Animal Health Act, 2002 (Act No. 7 of 2002)

⁵Regulations in Terms of Chapter 5 of the National Environmental Management Act, 1998 Regulation No. R. 385, No. R. 386, and No. R. 387.

 

1.4 International obligations

1.4(1)
The Waste Act section 6(1)(b), section 43(1)(b) and section 43(1)(d) specifies that the NWMS should give effect to South Africa’s international obligations in terms of waste management.

1.4(2)
The evolving system of international declarations, agreements and treaties has provided an important context for the evolution of South African environmental policy in general, and waste management policy in particular. The modern system of global environmental governance is to a large degree a consequence of the Rio Earth Summit 1992 and Agenda 21, which amongst others advocated four major waste-related programmes:

• Minimizing wastes.
• Maximizing environmentally sound waste reuse and recycling.
• Promoting environmentally sound waste disposal and treatment.
• Extending waste service coverage.

1.4(3)
The Summit set in motion a series of multilateral environmental agreements (MEAs) dealing with land-based sources of marine pollution, water quality, regional trans-boundary movement of hazardous waste, the management of toxic chemicals, and the trans-boundary movement of radioactive waste, amongst others.

1.4(4)
In relation to hazardous substances and waste, there are four principal conventions that apply:

• The Rotterdam Convention, acceded to by South Africa in 2002, sets out the procedure for Prior Informed Consent which promotes and enforces transparency in the importation of hazardous chemicals.
• The Basel Convention, acceded to by South Africa in 1994, addresses the need to control the transboundary movement of hazardous wastes and their disposal, setting out the categorization of hazardous waste and the policies between member countries.
• The Stockholm Convention on Persistent Organic Pollutants (POPs), which South Africa became a signatory to in 2001 and ratified in 2002, requires that member countries phase out POPs and prevent their import or export.
• The Montreal Protocol, to which South Africa became a signatory in 1990 and the amendments of which have been subsequently ratified, provides for the phase out of the production of certain substances in order to protect the ozone layer.

1.4(5)
The Basel Ban Amendment of 1995 has not as yet been ratified by South Africa. The ban protects developing countries and South Africa is currently considering how to address this amendment.

1.4(6)
There is a large body of relevant legislation which relates to each of these conventions, which is summarised in the following table:

Table 2: South African legislation impacting on four waste related international conventions

Relevant Legislation/Regulation	Montreal Protocol	Basel Convention	Stockholm	Rotterdam
Environment Conservation Act No.73 of 1989	X	X	X	X
Fertilizer, Farm Feeds, Agricultural Remedies and Stock Remedies Act No.36 of 1947	X		X	X
Hazardous Substances Act No. 15 of 1973	X	X	X	X
Health Act No. 61 of 2003		X	X	X
International Trade Administration Act No. 71 of 2003	X	X	X	X
National Environmental Management Act No. 107 of 1998	X	X	X	X
National Environmental Management: Air Quality Act No. 39 of 2004	X
Regulations for Hazardous Chemical Substances (GNR 1179 in GG 165996 of 258/1995)				X
Waste Act No. 58 of 2008		X
SARS Act No. 34 of 1997		X	X	X

1.4(7)
The Basel Convention is most directly relevant to the provisions of the Waste Act. Whilst there is no specific regulation in place to enforce it, the implementation of the convention is achieved primarily through the South African Revenue Service (SARS) and International Trade Administration Commission (ITAC) legislation and therefore additional legislation is not deemed necessary at present. Through measures to control the management and disposal of hazardous waste, the NWMS addresses the requirements of the Basel Convention in conjunction with other measures and outputs of the Waste Act, including hazardous waste related import and export policies, linked to tariff codes through SARS.
 
1.4(8)
SARS manages the assignment of tariff identity codes to various imports and exports. This tool is used to implement the various conventions. Unique tariff codes have been identified for the chemicals listed in the Montreal Protocol, and recently SARS identified tariff codes for the chemicals listed under the Rotterdam and Stockholm conventions. It is now possible to assign specific environmental controls or import restrictions to these chemicals. A similar process is underway for identifying codes for wastes listed in the Basel Convention. Identifying unique tariff codes for specific chemicals of concerns also enables imports and exports to be effectively monitored to ensure that they meet permitting requirements. SARS reports information annually to DEA on such measures in terms of a memorandum of understanding which is in place.
 
1.4(9)
A process of drafting an MOU between DEA and ITAC for control of imports and exports of MEA chemicals and wastes is underway. This will be facilitated by the allocation of tariff codes and use thereof, resulting in an integrated permitting process to manage the requirements of the three main MEAs.
 
1.4(10)
The Southern African Development Community (SADC) trade protocol contains provisions to lift financial and non-financial trade barriers between SADC members, which may pose a potential risk to the effectiveness of trade barriers for the import of hazardous waste. Article 9 of the protocol stipulates that existing trade barriers such as those relating to conservation of exhaustible natural resources and the environment, or trade barriers necessary to ensure compliance with existing obligations under international agreements, are not nullified.
 
1.4(11)
In relation to marine pollution, South Africa has acceded to a number of conventions which address dumping at sea and prescribe measures to prevent waste on land contaminating the seas and waterways. These wastes include oil, solid waste, nuclear waste and debris from landfill sites.

1.4(12)
Perhaps the most pertinent of these conventions is the London Protocol of 1996 (amended in 2006), which prohibits the dumping of certain hazardous wastes and provides for a permitting system for a number of identified materials and wastes. The oversight of this protocol and about fifty other maritime international conventions and agreements is undertaken by the International Maritime Organisation (IMO).

1.4(13)
Despite all the international maritime obligations, the quantities of waste deposited at sea do not appear to be diminishing. Possible reasons for this include low incidences of offenders being caught and brought to justice, combined with the disincentive for using port waste reception facilities (PWF) due to the additional charges for such facilities.
 
1.4(14)
The Montreal Protocol Treaty, revised in 1999, protects the ozone layer by phasing out the production of several substances which contribute to ozone depletion, with the aim of ozone layer recovery by 2050. This has some relevance for waste management in instances where such obsolete products enter the waste stream.

1.4(15)
Several obligations exist around measures to mitigate climate change. One of the roles that waste management can play in achieving these obligations is the reduction and efficient management of greenhouse gases released from waste at landfill sites.

1.4(16)
The South African government is required to put measures in place to give effect to the provisions of the MEAs to which the country has acceded. Section 5.5 will explore in more detail the mechanisms that are already operational or that will be established in relation to the waste related conventions.

 

1.5 Socio-economic and demographic context

1.5(1)
Socio-economic and demographic factors such as urbanization, unemployment and population growth impact on future waste trends and service provision. South Africa has a growing population characterized by both urbanization and the rapid development of the African middle class as historical injustices are redressed. Increasing affluence not only leads to an increase in the quantities of waste generated, but also leads to more complex waste flows. This trend towards more complex waste flows is reinforced by the continued industrialisation of the South African economy.

1.5(2)
In South Africa, growth in waste volumes is projected to rise to nearly 67⁶ million cubic metres by the year 2010 and rapid urban growth throughout the country is seriously outstripping the capacity of most cities to provide adequate waste services for their citizens.

1.5(3)
Over the next 50 years, South Africa’s population growth will be almost entirely concentrated in urban areas. If adequate waste management policies and practices are not implemented, cities will be overwhelmed by their own waste, seriously affecting the quality of life of all citizens. Household waste generation varies considerably by settlement type and income, with wealthier consumers in urban areas generating much higher volumes of waste. Urban residents typically also generate more non-organic waste, which is less conducive to on-site disposal. While 65% of South African households had access to domestic waste collection services in 2007, access to waste services remains highly skewed in favour of more affluent and urban communities⁷ .

1.5(4)
The persistent impact of social inequality informs the approach adopted by the NWMS, and which is echoed in the preamble of NEMA:

“the State must respect, protect, promote and fulfil the social, economic and environmental rights of everyone and strive to meet the basic needs of previously disadvantaged communities; inequality in the distribution of wealth and resources, and the resultant poverty, are among the important causes as well as the results of environmentally harmful practices”

1.5(5)
The implementation of effective waste management strategies will serve to develop the economic potential of the waste management sector, which has an estimated total expenditure of approximately R10 billion per annum⁸.  Both waste collection and the recycling industry make meaningful contributions to job creation and GDP, and there is the potential to expand these further.

1.5(6)
Well-considered, effective solid waste management systems can make critical contributions to public health, environmental sustainability, economic development and poverty alleviation by:

1. Improving public health outcomes (through removal of hazardous substances from the environment and reduced vectors for transmission of disease)
2. Enhancing environmental quality (through protecting watercourses and preventing degradation of public open spaces)
3. Reducing waste quantity that can clog up public storm water and sanitation networks (thereby reducing flooding, service failures and the need for maintenance)
4. Supporting higher levels of economic activity (through stimulating growth in waste sector, at the same time as avoiding over-regulation of the sector)
5. Contributing directly to poverty alleviation (through offering opportunities for employment, SMME development, and empowerment)

1.5(7)
The implementation of the NWMS will result in a number of clear socio-economic benefits, saving the country considerable resources in terms of public health and environmental degradation. The additional costs of implementing the Waste Act and the NWMS should be viewed against the considerable social, environmental and economic benefits that implementing the NWMS will have.

1.5(8)
The NWMS has to address the issue of the sheer volume of wastes produced by our society, at the same time as ensuring that waste management measures targeting the increasingly complex waste flows are environmentally sustainable and protect the health and well-being of the people. Accordingly the NWMS seeks to integrate the objectives of environmental sustainability and achievement of the waste hierarchy with the broader transformation and development objectives of improved public health outcomes, economic development, poverty alleviation and improved access for all.

Footnotes:

⁶Geoff Purnell of Munitech, “National Waste Quantification and the Waste Information System”, paper prepared for Department of Environmental Affairs as part of NWMS process, August 2009

⁷David Savage, “Cooperative Governance, Local Government and the Waste Planning System”, paper prepared for Department of Environmental Affairs as part of NWMS process, August 2009

^₈Michael Goldblatt of Palmer Development Group, “Macroeconomic trends, targets and economic instruments”, paper prepared for Department of Environmental Affairs as part of NWMS process, August 2009

1.6 Waste flows and strategic challenges

1.6(1)
In seeking to understand the main waste flows and the national waste balance, we are constrained by the existing data, which is in most cases unreliable, and in many cases, data originating from different sources is contradictory. Improving reporting standards at each level of the hierarchy of waste management is a priority challenge for the NWMS.

1.6(2)
Scientific understanding of the environmental hazards associated with waste flows has made significant advances in recent years. As a result, methods of disposing waste streams that were considered appropriate 20 years ago are in some cases now recognised as problematic.

1.6(3)
The overarching challenge of the NWMS is to address the growing pressure on outdated waste management infrastructure while at the same time improving the management standards that apply to particular waste flows. Specific categories of waste and the challenges associated with them are considered in more detail below.