Comments on National Waste Management Strategy
Submitted by Johan Schoonraad on Tue, 2010-08-10 13:52
EnviroServ welcomes a strategy that focuses on moving waste management up the waste hierarchy pyramid. While fully supporting such a strategy it should be pointed out as early as possible that all better waste management options will inevitably cost more than the current waste management practices followed in
These costs will inevitably be absorbed by industry, whether this is truly a manufacturing industry or an industry in the broader sense such as a municipal metro providing a waste disposal service, and pass these higher costs onto the consumer. These additional costs will therefore become an additional burden on the current tax base of South Africa which is already faced with increasing costs from higher electricity tariffs, toll fees on roads, carbon tax on new vehicle purchases, etc, etc. It has to therefore be debated whether the proposed “National Waste Management Strategy” has fully involved all Interested and Affected Parties (I&APs) impacted by the Strategy as I would be willing to venture that very few of the citizens of South Africa are even aware of the Strategy outside a few directly involved individuals in select industries, NGO groups and various Government departments.
The above general statement aside, the following have relevance to the “National Waste Management Strategy” document offered up for comment. These are either points for consideration or correction of blatant errata in the document.
1. Pg 9 of 155 – last paragraph – reads “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”.
The Waste Act is a ~48 page document, the National Waste Management Strategy is a ~155 page document, requiring substantial time to read and comment sensibly on. The Strategy document provides no viable link or searchable reference to the Municipal Finance Management Act, 2003, or the Municipal Systems Act, 2000 despite stating that these are significant documents that need to be read in conjunction to the Waste Act, presumably to fully understand the proposed Strategy. This is a major oversight.
2. Pg 11 of 155 – last paragraph of section 1.3 – reads “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.”
No such guideline document has been published
3. Pg 13 of 155 – 2nd last paragraph – reads “In relation to marine pollution,
The Strategy should fully explain what these are if comment into the Strategy is expected to be sensible, constructive and complete.
4. Pg 13 of 155 – last paragraph – reads “Perhaps the most pertinent of these conventions is the
As with point 1 as well as point 3 above, no viable link or searchable reference to this document is provided in the Strategy.
5. Pg 14 of 155 – 2nd last paragraph – reads “In
The figure provided does not seem to agree with that given on pg17, 2nd paragraph (“DEA’s figures for the 2006/7 financial year indicate that 24,115,402 tons of general waste was disposed of in landfills during that year”). The document is apparently unclear as to whether “waste volumes” is only municipal or includes all waste types.
6. Pg 15 of 155 – last paragraph, last sentence – reads “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”.
The “additional costs” and the “economic benefits” have not been quantified and it is therefore false logic to imply that these will only be positive impacts.
7. Pg 17 of 155 – 3rd paragraph, 3rd line – reads “In general, waste services and landfill management charges are underpriced, and a large proportion of municipal waste divisions are operating at a loss”.
Confirmation of the opening statement “that all better waste management options will inevitably cost more than the current waste management practices followed in South Africa”.
8. Pg 19 of 155 – paragraph on eWaste – reads “There is significant job creation potential in the recycling of eWaste, and several initiatives have and are being set up. The hazardous nature of this waste stream and the small margins of profit generated must be carefully considered when encouraging the recycling of WEE”.
The statement appears to be an oxymoron as there cannot be “significant job creation potential” if there are only “small margins of profit”.
9. Pg 20 of 155 – paragraph on Oil – reads “poly-aromatic hydrocarbons”.
Should read “polycyclic aromatic hydrocarbons”.
10. Pg 32 of 155 – 1st paragraph – reads “Approximately one and a half billion tons of packaging and paper waste….” .
This would be 1500 Million tons, in contrast to the “…nearly 67 million cubic metres by the year 2010” (point 5 above from Pg 14 of 155 in the Strategy). A significant disparity in numbers.
11. Pg 33 of 155 – 4th paragraph – reads “Product design which facilitates reduced hazardous components, reduced mixed materials, and ease of separation, is an important measure to support recycling”.
While the statement is correct, it needs to be debated how the Strategy can address this issue when so many products (electronic, automotive, household, etc) are imported and SA legislation has no impact on the “Product design”. This is particularly important when read in context with the sentence stating “The dti will complement product design initiatives by setting standards for the product in question”. This statement needs to be clarified as it could imply a ban or tax on imported products not deemed suitable or it could place unreasonable demands on SA products making them non-competitive with imported products.
12. Pg 37 of 155 – 2nd paragraph – reads “Labour intensive …….mechanisms for waste service delivery will be promoted by all spheres of government”.
“Labour intensive” could also be interpreted as “expensive” as labour is often the highest cost component of any business.
13. Pg 37 of 155 – paragraph 2.6 – the definitions offered in the paragraph should be quoted as in the Waste Act to avoid misunderstanding and should not be paraphrased.
14. Pg 37 of 155 – last paragraph, last sentence – reads “…landfill and waste treatment facilities tend to be located in close proximity to poor communities and informal settlements
The statement appears to imply that “landfill and waste treatment facilities” tend to move towards the “ poor communities and informal settlements” whereas the reality is almost always the opposite. Statement should be revised.
15. Pg 38 of 155 – 2nd paragraph – reads “In terms of waste treatment and processing, DEA supports the development of alternatives to landfill, including incineration, gasification, and pyrolysis.
The question would have to be asked then as to why the approval of cement kilns to use waste derived materials is being delayed via protracted EIAs if the DEA supports these alternatives and has developed a Policy governing such use? Compliance with the Thermal Policy as well as the relevant NEM:AQA emission standards should theoretically enable easy approval of such alternatives but this is not being seen in practice.
16. Pg 40 of 155 – 2nd paragraph, 7th line – reads “Once the standards for non-thermal HCRW treatment facilities have been developed….”
A distinction needs to be made between burn technologies such as incineration and other technologies that still use heat (ie. are “thermal” technologies) to sterilize HCRW. The general use of the term “non-thermal” could lead to confusion.
17. Pg 43 of 155 – last paragraph – reads “…a maximum fine of up to R10,000,000 million”
This is clearly a misprint as it implies a fine of R10 trillion rather than the R10 million intended.
18. Pg 44 of 155 – 4th last paragraph – reads “the Waste Classification and Management System will be in effect as of September 2010”.
The dates are incorrect or the DEA have been incorrectly informing stakeholders involved in the development of the System.
19. Pg 47 of 155 – last paragraph – use of “Waste Classification” and “Waste Categorisation” terminology.
The terminology is used incorrectly and needs to use the definitions contained in the proposed “DRAFT WASTE CLASSIFICATION AND MANAGEMENT REGULATIONS”.
“waste categorisation” means the grouping of waste into categories of major and specific general and hazardous waste types and the assignment of a corresponding category code in terms of the National Waste Information Regulations, 2010;
“waste classification” means establishing, in terms of SANS 10234, whether (i) a waste is hazardous based on the nature of its physical, health and environmental hazardous properties (hazard classes), as well as (ii) the degree or severity of hazard posed (hazard categories);
20. Pg 49 of 155 – Table 7 – Categories do not appear to agree with those given in the Waste Categorisation System for WIS Reporting
21. Pg 53 of 155 – last paragraph – reads “Access by the public and industry to information stored on SAWIS is considered vital”.
Many businesses would be uncomfortable with this as the information can be used by competitors to their advantage. The statement that “…proprietary company information is not exposed to third parties” can only apparently be guaranteed in Provinces where there are multiple companies generating similar waste streams.
22. Pg 62 of 155 – section 3.5.2 – reads “ … in terms of the now repealed ECA….”
The statement is misleading as according to our information there are still parts of ECA that have not been repealed.
23. Pg 87 of 155 – 3rd last paragraph – reads “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 statement is incorrect as the revision of Minimum Requirements is to address shortcomings identified in the 2nd and unpublished 3rd Editions and is not looking to “address new technologies and treatment options”.
24. Pg 96 of 155 – 2nd last paragraph – reads “Non-recyclable domestic batteries are encased in concrete and sent to landfill”.
Statement is incorrect. Most “Non-recyclable domestic batteries” are simply going to general waste landfill sites along with the domestic waste being disposed there.
25. Pg 98 of 155 – 2nd paragraph – reads “….are poly-aromatic hydrocarbons (PAH)”
See point 9 above. Should read “polycyclic aromatic hydrocarbons (PAHs)”.
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