4 Responding to waste category challenges

4(1)
The following section applies the above waste management measures and instruments to each of the main categories of waste described in Section 1.6 above.

4.1 Domestic and commercial general waste

4.1(1)
General waste is waste that does not pose an immediate hazard or threat to health or to the environment, and includes domestic waste, building and demolition waste, business waste, and inert waste.  The Waste Act defines ‘domestic waste’ as non-hazardous waste which emanates from premises that are used wholly or mainly for residential, educational, health care, sport or recreation purposes. Typically such waste contains foodstuffs, garden waste, old clothing, packaging materials such as glass, paper and cardboard, plastics, and, in certain cases, ash.  Business and commercial waste from offices, stores, and schools consists mainly of packaging materials such as glass, paper, plastics, and cans, with a limited quantity of foodstuffs emanating from hotels and restaurants.

4.1(2)
The mixed nature of general waste, the high proportion of recyclable materials going to landfill, and the presence of small quantities of hazardous waste are key challenges that need to be addressed. Where smaller industries are dispersed among normal commercial operations, regular monitoring is necessary to identify the need for special collection and disposal procedures.

4.1(3)
The reliability of domestic and business waste generation data will be systematically improved through the establishment of SAWIS. Data on different waste types in SAWIS will assist in understanding the sources and generation of different waste types, and characteristics and total volume of each waste stream.

4.1(4)
The Minimum Requirements for Waste Disposal at Landfills developed by the former Department of Water Affairs and Forestry regulate the measurement of general waste, including weighbridges at landfill sites depending on the classification of the landfill site. Where weighbridges are not currently available such as on communal waste disposal sites, alternative methods must be used to give a general estimate of waste volumes. 

4.1(5)
Various measures to aid the recycling of metal cans, paper, bottle glass and plastics have been described in earlier chapters, including waste separation and collection systems for recyclables. Specific measures to address scrap metal, window glass, appliance and eWaste are required. Based on the WCMS DEA will develop norms and standards regulating the storage, treatment and disposal of different waste categories.

4.1(6)
Earlier chapters have also dealt with various measures to improve the collection, transportation and disposal of general waste. These include:

  • Properly designing waste collection and transportation systems and choosing the correct type of vehicle
  • Measures to improve capital investment in waste collection vehicles and asset maintenance of waste machinery.
  • Measures to ensure properly planned, constructed, operated and maintained landfills.
  • Building capacity for compliance monitoring and enforcement in relation to disposal and landfill management.

4.1(7)
Wastewater sludge is a general waste stream that is regulated by the Waste Act in terms of the sludge disposal storage areas and in terms of the disposal of sludge ash.  Typical sludge management practices include dedicated land disposal, waste piling, landfill disposal and to a lesser degree use in agricultural practices. Even though sludge may only be present in the sludge handling and storage area for short periods at a time, it is, however, on a continuous basis. Hence the sludge disposal sites require a permit according to the Environmental Conservation Act and the Waste Act.  Landfill site owners and operators must manage the ash resulting from sludge thermal treatment accepted on the site as some ash can potentially be considered a hazardous waste as the ash may contain elevated concentrations of metals.  For ash disposal the producer and user must comply with the DWA Minimum Requirements Waste Management Series (Latest edition). Sludge management is a growing challenge for municipalities as a survey undertaken in 2001 of 72 wastewater treatment works from all provinces in South Africa (including cities through to small towns) indicated that approximately 670 tons of sludge per day may be generated.19  Just for these 72 facilities this equates to nearly 245 000 tons per year. Guidelines for the Utilisation and Disposal of Wastewater Sludge have been developed by DWA, and the implementation of these guidelines by municipalities, landfill site owners and operators is the main priority. The Guidelines provide information on how wastewater sludge can be used as a resource. Appropriate use of sludge as specified in the guidelines can generate a range of economic and social spin-offs to the benefit of local communities.

Footnotes:

19Purnell G (2009) National Waste Quantification and the Waste Information System. Research Paper commissioned for the National Waste Management Strategy.

4.2 Industrial and mining hazardous waste

4.2(1)
In terms of fulfilling the Waste Act’s objective of protecting human health and the environment from the negative impacts of waste, the regulation of hazardous waste is a key area of intervention in the national strategy. The Act defines hazardous waste as:

“…organic or inorganic elements or compounds that may, owing to the inherent physical, chemical or toxicological characteristics of that waste, have a detrimental impact on health and the environment …”

4.2(2)
In as much as they are regulated under separate legislation, certain classes of hazardous waste are not regulated by the Waste Act. These include:

  • Radioactive waste, which is regulated by the Hazardous Substances Act, 1973, the National Nuclear Regulator Act, 1999, and the Nuclear Energy Act, 1999;
  • Residue deposits and stockpiles from mining, which are regulated by the Mineral and Petroleum Resources Development Act, 2002;
  • Explosives, the disposal of which is regulated by the Explosives Act, 2003; and
  • Animal carcasses, the disposal of which is regulated by the Animal Health Act, 2002.

4.2(3)
It is noted that the regulatory framework for mining residue stockpiles and deposits is under review, and that in terms of the amendment to the Mineral and Petroleum Resources Development Act, responsibility for the performance of environmental authorisations will revert to DEA. This issue is dealt with more fully in Section 4.4 of the strategy.

4.2(4)
In terms of implementing the waste hierarchy for industrial and mining waste, waste avoidance and reduction is of particular importance due to the significant environmental impact of this waste, and the potential harmful consequences for human health. Where hazardous wastes cannot be avoided, emphasis needs to be placed on regulation, not only in defining standards for treatment and disposal, but also in ensuring reuse and recycling takes place in a safe and responsible manner.

4.2(5)
DEA is developing a new waste classification system to address new technologies and treatment options that replaces the DWAF Minimum Requirements for the Handling, Disposal and Classification of Hazardous Waste. The Waste Classification and Management System (WCMS) will be finalized in April 2011 and is central to the regulation of norms and standards for the management of hazardous waste. The WCMS hazard classes will be aligned with the SANS 10234 Globally Harmonised System, ordered in terms of Physical, Health and Environmental Hazards.

4.2(6)
The approach to classifying and categorising waste is described in Section 3.2 of the NWMS. The WCMS will prescribe the manner in which the waste is to be classified and treated. The WCMS will define waste types that will not be suitable for land application without prior treatment, and will establish the procedures and tests required to determine whether land application is acceptable. The WCMS will also identify acceptable uses of waste under particular circumstances.

4.2(7)
For example, samples from generators of waste must be tested for the most hazardous compounds in the waste. The samples will then be assessed against the globally harmonised system of hazard criteria to determine whether the waste is classified as general or hazardous. Based on the waste’s classification, the WCMS will provide a best practise technology guideline to assist in determining the most appropriate management options for the waste. The WCMS will provide a land application procedure that must be followed should land application be an option. This procedure which will include standard leach testing of the waste.

4.2(8)
Diverting hazardous waste from landfills is an important priority and DEA has recently finalised the National Policy on the Thermal Treatment of General and Hazardous Waste. The disposal requirements for hazardous wastes in the WCMS will be aligned with this policy, which:

  • Specifies air emissions standards for waste incineration in dedicated incinerators and as alternative fuels in cement kilns which are being formalized in the National Air Quality emission standards.
  • Specifies types of waste which may not be co-processed in cement kilns, which includes asbestos, bio hazardous wastes, unsorted electronic waste, batteries, and waste that has not been properly evaluated.

4.2(9)
Thermal treatment is a listed activity in terms of section 19 of the Waste Act, and licensing requirements in terms of section 19(3)(a) apply.

4.2(10)
Listing and licensing applies to the operation of landfills accepting all types of waste including hazardous waste. Currently, regional shortages of treatment and disposal facilities for hazardous waste exist and act as a constraint on economic growth. Accordingly, DEA will perform an assessment of current hazardous waste disposal capacity – both traditional landfills and incineration and co-processing – and seek ways to facilitate the private sector addressing shortfalls through expediting licensing processes and the application of economic incentives in conjunction with the dti and the National Treasury. DEA views industry as partners in regulation, and recognises that licensing of waste activities represents an administrative burden for industry and the state that is only practical once certain thresholds of waste volumes are attained.

4.2(11)
The mechanism for declaring priority wastes can also be used to entirely prohibit the generation of a particular waste. This is a useful tool to consider when implementing national obligations in terms of international conventions which require the safe management of waste steams containing banned or restricted chemicals.

4.2(12)
Initially, extended producer responsibility and consumer protection in relation to minimising hazardous industrial and mining waste will be addressed through voluntary initiatives. DEA has developed a National Cleaner Production Strategy, and will work with the dti, the National Cleaner Production Centre, and Indalo Yethu to encourage the uptake of cleaner production technologies by industry. To minimise the generation of hazardous waste, substitution of non-hazardous materials into production and manufacturing processes will be promoted.

4.2(13)
The effective regulation of hazardous wastes requires sufficient compliance and enforcement capacity on the part of DEA, and proposals in this regard are set out in Section 5.7 of the strategy.

4.3 Construction and demolition waste

4.3(1)
The primary issues in relation to construction and demolition waste are to address the problem of illegal dumping, divert this waste stream from landfills and properly manage hazardous waste components in this waste stream.

4.3(2)
Section 68 of the Waste Act stipulates substantial penalties for unauthorized disposal of waste, but on their own these will not sufficiently address the issue of illegal dumping of construction and demolition waste. A multipronged approach to the problem will be implemented, including the following elements:

  • Raising public awareness of the issue of illegal dumping.
  • Improving capacity to enforce national legislation and local by-laws in relation to illegal dumping.
  • Establishing and publicizing municipal hotlines for reporting illegal dumping.
  • Incorporating responses to this issue into municipal IWMPs.
  • Putting producers of construction and demolition waste in touch will potential users of such waste.
  • Diverting inert waste from landfill through the landfill acceptance criteria.
  • Promoting reuse through the acceptable use provisions of the WCMS.
  • Nelson Mandela Bay Municipality has established an online Waste Exchange System. Although the system is in its infancy, it provides a useful mechanism for private individuals and building contractors to link to potential consumers of construction and demolition waste.

4.3(3)
Although a percentage of this waste stream can be used as landfill cover, due to the volume of construction and demolition waste the priority is to promote recycling and reuse. There is extensive opportunity for recycling and reuse of construction and demolition waste as fill for road embankments, land reclamation and drainage control. Furthermore, when construction and demolition waste can be separated into its constituent components e.g. wood, metal, drywall, rubble, concrete and cardboard/paper, these can be reused as raw materials. The importance of correctly characterizing and separating construction and demolition waste is underlined by the presence of hazardous components such as asbestos in this waste stream.

4.3(4)
To achieve optimum levels of recycling and reuse, and to avoid the need for additional regulatory measures, it is suggested that stakeholders in the construction and demolition sector on a voluntary basis develop a sector-wide Industry Waste Management Plan, with particular attention placed on recycling and recovery, and the associated institutional arrangements funded by the construction industry to promote recycling and recovery and reduce illegal dumping. The ROSE foundation provides a useful model in terms of lubricating oil to be considered for application to the construction and demolition industry.

4.4 Mining waste

4.4(1)
General, hazardous and industrial wastes from the mining industry fall within the scope of the Waste Act, and therefore are addressed by the NWMS. Section 4(1)(b) of the Waste Act specifically excludes residue deposits and stockpiles from the scope of the Act, in as much as these are regulated in terms of the Mineral and Petroleum Resources Development Act, 2002, (MPRDA) – which falls under the aegis of the Minister of Mineral and Energy Affairs.

4.4(2)
Residue stockpiles are defined in the MPRDA as:

“any debris, discard, tailings, slimes, screening, slurry, waste rock, foundry sand, beneficiation plant waste, ash or any other product derived from or incidental to a mining operation and which is stockpiled, stored or accumulated for potential re-use, or which is disposed of, by the holder of a mining right, mining permit or production right;”

4.4(3)
A residue deposit is any residue stockpile that remains at the termination of a mining or prospecting activity.

4.4(4)
The MPRDA requires prospecting and mining operations to be conducted in accordance with the environmental principles set out in section 2 of NEMA, 1998 and provides further definition to this by establishing:

  • Liability for environmental damage and the responsibility to rehabilitate the environment is assigned to permit holders, and the need for applicants for permits to make financial provision for environmental liability.
  • Permit holders are required to receive environmental authorisation in terms of NEMA, which includes the requirement to submit an Environmental Management Programme that contains a waste management plan, and to comply with any prescribed waste standards.

4.4(5)
The 2008 Amendment to NEMA further defines the requirements for an Environmental Management Programme (EMPR). It further empowers the Minister of Mineral Resources to perform environmental functions in terms of NEMA that relate to mining activities (including prospecting, exploration and production). In respect to these activities, the Minister of Mineral Resources is empowered to:

  • Stipulate mining activities that require EIAs and EMPRs.
  • Evaluate EIAs and EMPRs.
  • Issue Environmental Authorisations.

4.4(6)
These parts of the amendment are scheduled to come into force 18 months after the proclamation of the NEMA amendment. Before they come into affect DEA will consult with DMR to determine whether the necessary capacity and administrative arrangements exist on the part of the DMR to fulfil the environmental functions that will be transferred.

4.4(7)
In relation to mining waste, the strategic focus in terms of the waste hierarchy is on ensuring the treatment and safe disposal of mining waste. However, opportunities for reuse of mining waste need to be fully exploited.

4.4(8)
It is in the interests of industry and good governance that norms and standards that apply to acceptable uses are developed for the storage, transport, disposal, reuse, treatment and processing of residue stockpiles and deposits. In relation to ash, for instance, it is necessary for standards for toxicity to be developed to ensure that potential re-use in brick-making or as cement extender does not pose a risk to health.

4.4(9)
“Residue stockpiles” constitute a heterogeneous category of actual or potential waste substances. DEA will engage with DMR to determine if a memorandum of understanding is possible to classify residue stockpiles with the framework of the WCMS.

4.4(10)
Appropriate waste management options for mining waste which falls outside of the Waste Act should be identified in an IndWMP for the mining sector. The central purpose of the plan will be to establish waste management guidelines and targets for the mining sector with which EMPRs must be aligned. In terms of the framework for IndWMPs described in Section 3.4 of this strategy, the waste management plan in an EMPR corresponds to a site-level IndWMP.

4.4(11)
Institutional responsibility for the drafting of the mining sector plan will lie with the Chamber of Mines, who will be required to undertake a public consultation process in drawing up the plan. In approving or amending the Mining Sector IndWMP, the Minister for Environment Affairs will consult with the Minister of Mineral Resources.

4.5 Health care risk waste

4.5(1)
Due to the significant risks associated with Healthcare Risk Waste (HCRW) and the strategic challenges outlined in Section 1.6, this is an area of priority for regulation in terms of the Waste Act’s provisions for listed waste management activities. This will, in turn, impact on the Department’s capacity requirements in terms of its responsibilities for monitoring, compliance and enforcement.

4.5(2)
In terms of implementing the waste hierarchy, the key challenges in terms of health care risk waste management lie in the safe treatment and disposal of this waste.

4.5(3)
These challenges need to be addressed on the basis of accurate information on quantities of HCRW to ensure that scarce government resources are efficiently allocated in addressing capacity shortages. The Department will seek to achieve full compliance of all thermal HCRW treatment facilities within 3 years of the gazetting of the air quality standards. Facilities that are unable to achieve compliance will be required to produce plans for their decommissioning within 1 year of the date on which the air quality standards came into effect.

4.5(4)
Once the standards for non-thermal HCRW have been developed through the HCRW regulations, all permits for non-thermal HCRW treatment facilities will be reviewed to ensure alignment and compliance. Where non-thermal HCRW treatment facilities are not able to comply plans for their decommissioning within one year of the publication of the HCRW regulations with a view to decommission within three years of the gazetting of the HCRW regulations.

4.5(5)
In addition to aligning with the overall objectives of the Waste Act, the regulatory priorities for the HCRW sector are:

  • Establish reporting requirements and thresholds for SAWIS for the generation, treatment and disposal of this waste. To this end, HCRW has been included as a primary category in SAWIS.
  • HCRW is also considered a pre-classified waste in terms of the WCMS.
  • Systems to facilitate segregation within health care institutions have been developed for the rural and urban environment and have been piloted at institutions within these settings. In order to achieve the desired level of segregation these systems are to be rolled out to healthcare institutions nationally.
  • Define safe, measurable and achievable minimum standards for the storage, collection, and transport, for HCRW management. These will include standards for new treatment procedures including low-heat thermal treatment, chemical, irradiative and biological processes in addition to incineration.
  • Implement the performance standards for thermal treatment technologies which are being formalised through the air quality emission standards process and develop performance standards for non-thermal technologies through the HCRW regulations development process.

4.5(6)
The Policy on Health Care Risk Waste Management being developed by DEA indicates that each health care institution must develop a HCRW management plan to ensure that HCRW is managed in a manner which is protective to third parties and which is environmentally sound.  This plan must include the appointment of healthcare waste officers, provide information on waste quantities and management measures, and awareness and training programmes.

4.5(7)
A differentiated approach that distinguishes between major and minor generators will be adopted to ensure regulation that is both practical and protects the public from exposure to HCRW. Differentiation will be based on the types and quantities of wastes generated, and will take into account the risk posed by even small quantities of HCRW. Individual medical practitioners must be issued with receipts by accredited licensed HCRW facilities that indicate the quantity and type of waste disposed. This will be enforced by the Medical and Dental Council, with the requirement to present such receipts becoming part of annual registration procedures for medical practitioners.

4.6 Pesticide waste

4.6(1)
Pesticide waste generated by the agricultural sector consists amongst others of: herbicides, insecticides, fungicides, seed treatments and plant growth regulators as well as the containers used to store them. Despite being a relatively ‘small’ waste stream in quantity, these are highly toxic chemicals which may bio-accumulate in the food-chain and have major health consequences should they not be used and managed appropriately.

4.6(2)
An approximated stockpile of 700 tons of residual pesticides and containers have accumulated in farming areas which require treatment disposal and in some instances remediation of contaminated land.
In terms of implementing the waste hierarchy, the immediate focus for this waste stream needs to be on safe treatment and disposal.

4.6(3)
South Africa was identified as one of 7 countries to implement an Africa Stockpiles Programs which aimed to collect and safely dispose of obsolete and unwanted pesticides in Africa. A pilot project was undertaken in the Limpopo province where approximately 80 tons of stocks were collected. These pesticides will be shipped for incineration and disposal internationally. Remaining funds will be used to collect pesticides in an additional two provinces.

4.6(4)
The agricultural and veterinary industry through their Agricultural and Veterinary Chemicals Association of South Africa (AVCASA) has been identified as  one of the first four industries that have been requested to produce an IndWMP in order to identify how the industry will minimise, manage and fund the management of their waste stream.

4.6(5)
AVCASA proposes that funds will be raised via a levy which is placed on each drum sold. The funds will be collected by the manufacturers and managed by AVCASA. Funds will also be used to remediate pre-existing contamination.

4.6(6)
On acceptance of an IndWMP DEA will develop a supporting regulation relating to the proposed AVCASA levy.

4.7 Fly ash and coarse ash waste

4.7(1)
Eskom produced 34,160,000 tons of fly ash in 2007, of which 6% was reused. Since Eskom is planning to expand its coal-powered generating capacity, quantities of fly ash waste will increase. In the same year Sasol produced an approximate 10,000,000 tons of coarse ash per year as a result of coal gasification processes.

4.7(2)
The national strategy seeks to achieve waste reduction through the treatment, reuse and beneficiation of fly ash and coarse ash. To facilitate this, the WCMS will provide for acceptable uses of waste. Industry will determine appropriate and environmentally sound uses of various grades of ash which will then be assessed by Government and stakeholder through the “acceptable use” process and depending on suitability these uses will be identified in terms of section 19 (3) of the Waste Act i.e. activities not requiring licensing. A wide range of potential uses for fly ash have already been identified, including treatment of acid mine drainage and stabilisation of sludge from a variety of industrial processes. Commercial exploitation of fly ash in brick-making and cement and concrete has already begun. The public benefit and economic potential for reuse of this waste stream is significant. Industry will be able to explore further reuse applications and assess these uses against the acceptable use criteria provided for within the framework of the WCMS.

4.8 Tyres

4.8(1)
Waste tyres have been identified as a problematic waste stream as they are not compactable or degradable and prove problematic at landfills, with some sites historically refusing to accept them, and others charging higher fees for allowing their disposal.  This, in part, has caused a large amount of illegal dumping and burning of tyres to recover steel for recycling, resulting in toxic air emissions and unsightly tyre stockpiles which prevent other land uses.

4.8(2)
In terms of implementing the waste hierarchy, the strategic focus is on diverting tyres from landfill through recycling and the promotion of treatment and processing technologies.

4.8(3)
There are at present 12 plants which can process waste tyres into a possible 250 products although at present the supply of waste tyres exceeds the demand. A potential use for waste tyres which exceed recycling demand is in the use of the energy potential of waste tyres in combustion processes, for example cement kilns. The cement industry has identified this use of waste tyres as a potentially beneficial alternative fuel and several kilns are currently applying for environmental authorization for this activity.

4.8(4)
In 2002, the tyre industry formed the South African Tyre Recycling Process Company (SATRPCo), a section 21 company, which aims to manage the collection and distribution of waste tyres to recycling and reprocessors on behalf of the tyre industry. The procedures for the management of this waste stream have been identified in a draft IndWMP produced by the SATRPCo which is currently in a consultation phase. The plan must give effect to the waste hierarchy i.e. recycling must receive priority as a waste management option.

4.8(5)
The waste tyre regulations which came into effect on 30 June 2009 require all producers and importers of tyres to submit an IndWMP for approval by the Minister, or to register with an approved IndWMP. The IndWMP must indicate how the tyres are to be managed and how management will be financed once the tyres become waste. The regulations also require that waste tyres with load index of 121 be rendered unusable. DEA will consider and approve the IndWMPs submitted by producers and importers. Organisations recycling and recovering the energy potential of waste tyres must report the quantities of waste tyres they process to the SAWIS.

4.8(6)
Whilst it is thought that waste tyre recycling could potentially create jobs, the market demand for related products will need to be stimulated in order to achieve this. As part of the process of compiling the IndWMP, industry is requested to research potential mechanisms for market stimulation, and make proposals to DEA and the dti.

4.9 eWaste

4.9(1)
eWaste refers to Waste Electrical and Electronic Equipment (WEEE). This waste stream is relatively new, rapidly growing, and in some cases highly hazardous due to heavy metals content. There are currently no reliable statistics for the amount of eWaste generated or recycled. With the increase of consumerism and the rise of the information age, eWaste will continue growing exponentially, and rapidly become a major waste challenge. WEEE can contain over one thousand different substances, many of which are toxic and some that have a high market value when extracted. There are seven recognized sub types of eWaste as per the Waste Classification System. Lighting equipment is one of these seven types and will be considered as a separate waste stream due to the specific mercury content issue and related IndWMP being prepared specifically for this waste stream. The other six sub types should be considered individually within the eWaste stream and where appropriate individual measures for each sub type may be required.

4.9(2)
In terms of implementing the waste hierarchy, the main challenge lies in separating this waste from general waste to facilitate safe and economically sustainable recycling of this waste stream.

4.9(3)
Informal recycling of eWaste is relatively prevalent, but often done without safety equipment, resulting in potential harm to health, and contamination of the recycling site, as well as the release of noxious fumes through the burning of plastic to access the valuable metals inside the equipment. Formal recycling is typically a partially mechanized process which separates materials, whilst WEEE is often dismantled by hand and then separated before shredding. Some mechanized processes do not necessarily allow for re-use or refurbishment, as the whole object is put through a shredder, and the shredded output is then mechanically separated using water, air or magnetism. The separated shredded plastics and metals are then sent for reprocessing as recyclates.

4.9(4)
In July 2008, the eWaste Association of South Africa (EWASA), a section 21 company, was established to set up an environmentally sound eWaste management system, utilizing various programmes and networks. Membership of EWASA is R2000 per year for recyclers.

4.9(5)
The two major emerging initiatives are voluntary take-back facilities at retailers which in turn increases recyclate availability, and a recycling fee on imported goods which may result in eWaste. This levy will be managed and regulated via industry. At present some retailers are agreeing to voluntary take-back facilities. Such facilities at electrical and electronic goods retailers should be mandatory and subject to an IndWMP for the eWaste industry.

4.9(6)
EWASA will form a section 21 company to manage a 10% recycling fee charged on all imported goods which will result in eWaste. At present it is a voluntary fee and requires the manufacturer to declare imports to EWASA, who will then compare the data with customs to ensure the correct amount is paid. Whilst several large electrical and electronic brands have agreed to this voluntary scheme, it should be formalized in terms of an IndWMP, and be made universally applicable through mandatory measures, to ensure that there are no free-riders within the industry.

4.9(7)
The use of take-back facilities is at present voluntary, meaning some eWaste still goes to landfill or the informal recycling process. DEA will make it a legal requirement for consumers to utilize these take-back facilities through regulations requiring producers and importers of WEEE to develop IndWMPs or to register with approved plans. 

4.9(8)
DEA will develop standards for the storage, treatment and disposal of electronic waste as part of the process to develop norms standards in terms of section 7(1)(c) of the Waste Act.

4.9(9)
Further research must be undertaken by industry regarding the appropriate measures to protect the health and safety of the informal recyclers currently handling eWaste while seeking to protect their livelihoods. At present EWASA membership is likely to be too expensive for most informal recyclers, and therefore ways of redressing disincentives such as this and the limited accessibility of EWASA schemes (such as the online booking system which facilitates recyclers ‘booking’ the retailers that they wish to collect waste goods from) should be developed by industry.

4.9(10)
The SAWIS categories have been expanded to include 7 categories for reporting on e-waste. 

4.9(11)
The measures set out in this section are to be contained within an IndWMP, produced by industry. The IndWMP will provide for mandatory take-back facilities at retailers, the process of formalizing the informal recycling practices, and the reporting requirements to the SAWIS. 

4.10 Batteries

4.10(1)
There are an estimated 50 million batteries sold in South Africa each year. Whilst some are rechargeable batteries, the majority are alkaline and silver oxide batteries which are not rechargeable. Various heavy metals including mercury and cadmium are present in these batteries, resulting in their classification as hazardous waste.

4.10(2)
In implementing the waste hierarchy, the key challenges are to reduce this waste stream through recycling, and where recycling is not possible, to separate this waste from the general waste stream so it can be disposed of safely. The Waste Classification System provides for seven sub categories of batteries, and appropriate waste management measures need to be applied to each subcategory.

4.10(3)
Currently, there are no regulations or official EPR initiatives in place for the domestic battery industry. One international supplier of domestic batteries has begun a battery recycling initiative, with collection bins placed at selected outlets. These batteries are then sorted and the recyclable batteries are sent to France as there are currently no domestic batteries recycling facilities in South Africa. Non-recyclable domestic batteries are encased in concrete and sent to landfill.

4.10(4)
The South African Battery Manufacturers Association manages a scrap loading charge, or levy, on motor vehicle batteries, which are considered toxic due to the lead and sulphuric acid content. Battery retailers will generally take back one battery for every new battery bought from them, and will return the levy in exchange. The levy ranges from approximately R10 for motorbike batteries, to R100 for motor car batteries. Breakthroughs in technology have resulted in the components of these batteries becoming almost 100% re-useable or recyclable, and the levy has assisted in high levels of motor vehicle battery recycling.

4.10(5)
Standards for ensuring that batteries sold in South Africa meets international specifications should be set out through a SABS standard in consultation with the dti.. These standards will then be legislated for in terms of section 18(2) of the Waste Act. Further research is required in order to explore potential synergies between various eWaste initiatives including batteries.

4.10(6)
The battery industry will be required to produce an IndWMP which must among other requirements provide for an education and awareness campaign for the general public, with the aim of decreasing the number of batteries going to landfill, and promoting the use of rechargeable batteries as well as the recycling of batteries.

4.10(7)
Should the IndWMP fail to be effective, a mandatory EPR programme will be considered by DEA.

4.10(8)
Local facilities for recycling of batteries should be established in order to reduce the environmental and economic impact of sending them abroad whilst benefiting economically from the recycled product. Industry should set out a plan within the IndWMP for the development of such facilities. The requirement and provision of subsidies or other financial incentives to initially establish these facilities could then be considered by the dti with input from DEA.

4.11 Fluorescent lamps containing mercury

4.11(1)
Lighting equipment is considered a sub type of Waste Electric and Electronic Equipment (WEEE) according to the Waste Categorisation System. Whilst WEEE or eWaste is considered as a waste stream within this strategy, due to the nature of the industry and consideration of the existing IndWMP, lighting equipment is considered separately. The use of Compact Fluorescent Lamps (CFLs) is a growing trend in South Africa due to their energy efficiency, which is an important consideration in a country which is experiencing mounting energy prices and shortages. However, CFLs are regarded as hazardous due to their mercury content and must be managed appropriately.

4.11(2)
Currently there are no facilities to collect and manage CFLs separately and they are disposed of with domestic waste. In terms of implementing the waste hierarchy, the immediate focus for this waste stream is on preventing the unsafe and environmentally harmful disposal of CFLs.

4.11(3)
Standards for the handling and recycling of CFLs are to be developed in support of the IndWMP to ensure safe and environmentally sound handling, recycling and disposal. These will be developed as part of the development of norms and standards for the storage, treatment and disposal of waste to be developed in terms of section 7(1)(c) of the Waste Act.

4.11(4)
It is recommended that the IndWMP being produced includes the formalization of informal recycling practices within the sector and a take-back scheme for mercury containing lamps be produced by the industry.

4.11(5)
Where feasible, synergies between lighting initiatives and other eWaste initiatives should be sought in order to streamline activities.

4.12 Lubricating oil

4.12(1)
Whilst just over half of the lubricating oil sold in South Africa is consumed through use, the remaining 40% to 45% is highly threatening to the environment and human health if incorrectly disposed20. The breakdown of additives and base oil releases and mixes a variety of chemicals in the used oil, the most harmful of which are poly-aromatic hydrocarbons (PAH) which potentially have carcinogenic effects. Used oil poses an especially serious threat to drinking water supplies and aquatic life, with one litre of used oil able to pollute one million litres of water.

4.12(2)
The Recycling Oil Saves the Environment (ROSE) Foundation, a section 21 company, manages the collection, storage and recycling of used lubricating oil. ROSE is funded through levies of 5c per litre of oil sold from manufacturers and marketers of lubricants, and the sale of the oil it has recycled. ROSE uses the levy to pay collectors 10c per litre of used lubricating oil collected. ROSE is currently acquiring PBO status. ROSE established the National Oil Recycling Association of South Africa (NORA-SA) in 2005, which has 90 members.

4.12(3)
NORA-SA’s members have endeavored to provide receptacles for used oil, educational campaigns and training for all ROSE collectors. It is vital that all users of lubricating oil, including garages and the motor vehicle maintenance industry, are obliged to dispose of used oil according to certain standards, aligned with the ROSE initiative for the collection and recycling of oil. Such standards will be developed in terms of Section 7(1)(c) of the Waste Act, as part of the process to determine standards for the storage, treatment and disposal of different categories of waste.

Footnotes:

 20PURNELL, Geoff. 2009. National Waste Quantification and Waste Information System.[Online]. Available:  http://www.wastepolicy.co.za/nwms/library/index.htm [17 February 2010]