3.2 Waste classification and management system

Chapter 2, Part 2 of the Waste Act requires that national norms and standards for the classification of waste should be developed. The waste classification and management regulations provide a waste classification system for all wastes managed under the Waste Act. Waste is to be classified according to the Globally Harmonised System of Classification and Labelling of Chemicals (GHS)⁴⁰. GHS classifies hazardous substances according to the type and degree of risks that chemical compounds in different physical states (i.e. solid, liquid or gas) pose to human health and the environment.

Waste streams that are clearly identifiable will be pre-classified. Waste generators will not need to classify these wastes in terms of the WCMS. Examples of pre-classified wastes include domestic waste, uncontaminated building and demolition waste, business waste collected by municipalities, tyres, garden waste, post consumer packaging, asbestos wastes and health care risk waste.

The waste classification and management regulations set timeframes in which waste must be classified and managed, including wastes stored in lagoons. The regulations prohibit the mixing of waste prior to classification and require that co-disposal of domestic waste and industrial waste be phased out. Timeframes are also set for the phase out of macro encapsulation of waste.

Section 19(3)(a) of the Waste Act specifies that the Minister may, by notice in the gazette, indicate:

1. whether a waste management licence is required for listed waste management activities; and
2. the requirements or standards that will apply to listed activities for which licensing is not required.

To encourage re-use and recovery of industrial wastes the WCMS establishes a procedure for submitting motivations to the Minister for the listing of waste management activities that do not require a waste management licence. In the motivation to the Minister the applicant must provide details of local and international specifications or standards relating to the waste and the waste management activity⁴¹ as well as supply proposed requirements or standards specific to the waste management activity that would ensure that the activity can be implemented and conducted consistently and in a controlled manner⁴². The use of slag as aggregates for road building and the use of ash for cement extenders and brick making are good examples of wastes activities for which licences may not be required should certain requirements be fulfilled.

The WCMS regulations will replace the DWAF Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste. For hazardous waste, the WCMS institutes a management system consisting of waste manifests, safety data sheets, container labelling and detailed storage records:

• All generators of classified hazardous wastes must complete a waste manifest document that accompanies the waste until a manager at the point of disposal issues a receipt for the waste on the manifest.
• Apart from the waste manifest, the WCMS requires that a safety data sheet⁴³ accompanies all hazardous wastes, including contaminated general waste.
• Containers that store hazardous wastes must be labelled and storage facilities must keep detailed records.

This system will improve the management and quality of data available on hazardous wastes and ensure reporting to SAWIS.

The WMCS includes two new standards: the Standard for Assessment of Waste for Landfill Disposal and the Standard for Disposal of Waste to Landfill.

The first standard contains the requirements to assess the level of risk associated with the disposal of waste to landfill. The level of risk is based on identifying contaminants present in the waste and comparing these with determined limit values⁴⁴. The second standard provides for landfill classification and containment barrier design requirements⁴⁵, which supersede the liner design requirements for landfills contained in the Minimum Requirements for Waste Disposal by Landfill⁴⁶. The standards also include waste disposal restrictions and timeframes in which the wastes may no longer be disposed to landfill. This will encourage the development of alternative options for the management of these waste streams.

40. As specified in SANS 10234
41. Regulation 9(g)
42. Regulation 9(l)
43. In accordance with SANS 11014
44. Both the total concentrations (TC) and the leachable concentrations (LC) for specified contaminates are to be determined. These concentrations must then be compared to the four levels of threshold specified. Risks are associated with each threshold. The standard prescribes the test methods for both the total concentration tests and the leachable concentration tests.
45. It provides for containment barrier designs, for class A, B, C and D wastes and identifies which type of waste can be disposed on which liner design. Furthermore, the disposal of very high risk waste to landfill is not allowed. The waste must be treated and re-assessed. High risk waste may be disposed of to a Class A landfill design. Moderate Risk waste to a Class B landfill design. Low Risk Class C landfill design. Inert Waste Class D landfill design.
46. 2nd Edition, 1998; Department of Water Affairs and Forestry