SUBMISSION
BY Groundwork
Why the SA Waste Bill legislation must proscribe incineration and detail
better waste management options
Some pointers for Portfolio Committee on Environment and Tourism for National
Environmental Management: Waste Management Bill
Threats to health and recycling
Landfill sites are a serious problem in South Africa today.
·
Because
of non-compliance;
·
DWAF
takes a more 'conciliatory' and 'cooperative governance role' in their duty to
enforce;
·
There
are not sufficient funds set aside by government to have efficient landfills and
waste management systems that will support recycling, reuse and recover;
·
DEAT
has not got the people power to respond to these challenges; and
·
DEAT
and DWAF have still not finalised exactly who takes responsibility where with
regard to landfill sites. We need to deal with this as an urgent issue, not
consider the outside possibility that incineration will solve this problem.
General
Health Hazards Associated with Incineration
·
Creates
toxic ash and other residue;
·
Emits
very small particles (PM 2.5 to PM 1);
·
Particles
travel long distances and penetrate deep into the respiratory system, where
they cause increases in mortality from a range of cardiac and vascular
diseases and cancers:
·
It
takes 5 years for the human body to excrete half of these particles. Healthy lungs
retain about 50% of fine particles to which they are exposed [1].
·
Particles
coated with toxic metals and organic compounds can impact upon lung chemistry
(particularly likely when the particles come from incinerators). The chemicals
coating the surface of the particle erode off in the lungs and are then
transported through the lining of the lung into the bloodstream.
·
Even
when the ultrafine particles are not particularly toxic, there is strong
evidence that they can initiate "oxidative stress" a process which
alters lung cell chemistry, causing inflammation and setting in motion health
problems. [1] & [2] Increase chance of heart attacks and strokes. [3]
Failure of
control equipment
·
Fine
and ultrafine particles are too small to be captured by filters and even the
most modem air pollution control devices installed in incinerators cannot do
so. The commonly-used bag-house filters trap only the coarser ultrafine
particles, allowing 70-95% of the more dangerous PM2.5 particles to escape. [4]
Persistent
Organic Pollutants (dioxins and furans - Stockholm Convention)
·
Incineration
of waste produces hundreds of chemicals. Some are released into atmosphere, and
some are in ash, which is dumped on landfill sites
·
These
substances are lipophilic and accumulate in fatty tissue and remain active in
the living organisms and the environment for many years. They have been linked
with early puberty [5], endometriosis [6], breast cancer [7, 8], reduced sperm
counts [9] and other disorders of male reproductive tissues [10], testicular
cancer (9) and thyroid disruption [11, 12]. It has been claimed that about 10%
of manmade chemicals are carcinogenic, and many are now recognised as
endocrine disrupters. Most of these health effects were not anticipated and are
only now being recognised. No safety data exist on many of the compounds
released by incinerators.
Incineration
will:
·
Not
clean up the waste they are fed. If mercury and other heavy metals go in, heavy
metals come out;
·
Produce
dioxins and other persistent, bio-accumulative and toxic compounds which are
trapped in bottom and fly ash or released into the atmosphere; and
·
There
is a growing body of evidence strongly suggesting that communities living close
to incinerators suffer increased incidences of cancer and respiratory problems.
[13,14,15,16,17,18].
Waste-to-energy
as 'recovery plants'. In June 2007, the European Council decided to support the
European Commission's proposal to reclassify efficient waste-to-energy
incinerators as recovery plants. This decision is based upon modern
efficient incinerators of which there are none in SA.
Medical waste incinerators were the largest source of Dioxin emissions in the
US in the 1990s and 1980s. They were the second largest source of mercury
emissions. These figures have dropped because of a move towards alternative
processes of dealing with medical waste.
If all the medical waste incinerators were subject to the Air Quality Act, and
even the permit possibilities under Air Pollution Prevention Act, they would be
non-compliant with a health based standard. This in itself is significant as
there are no plans to make these MWI more efficient than they currently are -
in a sense a health hazard to people who live around them!
Incineration will contradict the following Principles already
in the waste bill:
·
[The
Principle] "Best practicable environmental option" means the most reasonable
measure for providing the greatest positive impact and least negative impact
on health and the environment; and
·
No
person may "[section 26] (b) dispose of waste in a manner likely to cause pollution
of the environment or harm to health and well-being."
Chapter 5
of the waste Bill: Licensing of waste management activities, section 48
details the:
"Factors to be taken into account by licensing authority
48. When considering an application for a waste management licence, the
licensing authority must take into account all relevant matters, including-
(b) the pollution caused or likely to be caused by the activity that is the
subject of the application, whether alone or together with existing operations
or pollution and the effect or likely effect of that pollution on the
environment, including health, social conditions, economic conditions and
cultural heritage;
(c) the best practicable environmental options available and alternatives that could
be taken -
(i) to prevent, control, abate, or mitigate pollution; and
(ii) to protect the environment, including health, social conditions, economic
conditions and cultural heritage from harm as a result of the undertaking of
the waste management activity;
(e) whether the applicant is a fit and proper person as contemplated in
section 59;"
This section taken directly from the Waste Bill is clearly counter intuitive to
permitting a waste management activity such as incineration because of the
inherent uncertainty associated with incineration. Our recent experience of
medical waste incineration in Gauteng further reinforces this belief.
Conclusion
The Waste Bill must guarantee separation of waste streams and
channelling them towards the most efficient treatment processes (such as
recycling). Why incentivise incineration when there are better alternatives?
Cases from around the world, including Kerela (India), Cairo (Egypt), San
Francisco, Boulder (US), Canberra (Australia), Novara, Treviso, (Italy), Molins
de Rei, Tona, Blanes (Spain), prove that segregation, composting, re-use and
recycling programmes can reduce the waste stream to a level that renders
incineration unnecessary.
All incineration does is develop another field in which DEA T needs to get the
necessary expertise, knowledge and extra people power to manage and deliver
enforcement in this complex field. First get the management of present problems
secure, then consider what you can add on your plate.
References
[I] Hughes, Lara S., and others. "Physical and Chemical Characterization
of Atmospheric Ultrafine Particles in the Los Angeles Area." Environmental
Science & Technology Vol. 32, No.9 (1998), pgs. 1153-1161
[2]. Donaldson, K. and Stone, V. Current hypotheses on the mechanisms of toxicity
ofultrafne particles, Ann 1st Super Sanita 2003;39(3):405-410
[3] Dick, Colin AJ. et al. "The Role of Free Radicals in the Toxic and Inf
ammatory Effects of Four Different Ultra fine Particle Types." Inhalation
Toxicology Vol. 15, (2003), pgs. 39-52.
[4] UK Environment Agency. Determination of an Applicationfor a PPC Permit
under the Pollution Prevention and Control (England and Wales) Regulations 2000
(S12000 No.1973). Decision Document recording the decision-making process.
November 2006 (ppe Permit No. BV8067IL). p.24
[5] Den Hond E, Roels HA, Hoppenbrouwers K et al. Sexual maturation in
relationship to polychlorinated aromatic hydrocarbons: Shape and Skakkebaek's
hypothesis revisited. Environ Health Perspect 2002; 110(8): 771-6.
[6] Eskenazi B, Mocarelli P, Warner M et al. Serum dioxin concentrations and
endometriosis: a cohort study in Sevenso, Italy. Environ Health Perspect 2002;
110(7): 629-34.
[7] WolffMS, Weston A. Breast cancer risk and environmental exposures. Environ
Health Perspect 1997; 105(Suppl 4): 891-6.
[8] Hoyer AP, Granjean P, Jorgensen T et al. Organochlorine exposure and the risk of breast
cancer. Lancet 1998; 352 (9143): 1816-20.
[9] Oliva A, Spira A, Multigner L et al. Contribution of environmental factors
to the risk of male infertility. Hum Reprod 2001; 16(8): 1768-76.
[10] Sultan C, Balaguer P, Terouanne Bet al. Environmental xenoestogens, anti
androgens and disorders of male sexual differentiation. Mol Cell Endocrinol
2001; 178 (1-2): 99-105.
[11] Hardell L, van Bavel B, Lindstrom G et al. Increased concentrations of
polychlorinated biphenyls, hexachlorobenzene and chlordanes in mothers of men
with testicular cancer. Environ Health Perspect 2003; III (7): 930-4.
[12] Tomatis L. Transplacental Carcinogenesis. Lyon, International Agency for
Research on Cancer, IARC Scientific Publications No 4 ppl 00-111.
[13] Michelle Allsopp, Pat Costner and Paul Johnston, (2001) Incineration and
Human Health: State of Knowledge of the Impacts of Waste Incinerators on Human
Health - (Executive Summary), ESPR - Environ Sci & Pollut Res 8 (2)
[14] Viel, J-F., Arveux, P., Baveret, J., Cahn, J- Y. (2000) Soft Tissue
Sarcoma and Non-Hodgkins Lymphoma Clusters Around a Municipal Solid Waste
Incinerator with High Dioxin Emission Levels. Am J Epidemiol Vol.I52 No I
[15] Floret, N., Mauny, F., Challier, B., Arveux, P., Cahn, J.-Y., Viel, J.-F.
(2003). Dioxin emissions from a solid waste incinerator and risk of non-Hodgkin
lymphoma. Epidemiology 14: 392-398
[16] Knox, E.G. (2000) Childhood Cancers, birthplaces, incinerators and
landfill sites. International Journal of Epidemiology 29: 391-397
[17] Saintot, M, Malaveille, C, Hautefeuille, A, Gerber, M. (2004) Interaction
between genetic polymorphism of cytochrome P450-I BI and environmental
pollutants in breast cancer risk. European Journal of Cancer Prevention.
13:83-86
[18] Elliott, R, Shaddick, G., Kleinschmidt, L, Jolley, D., Walls, R,
Beresford, J. & Grundy, C. (1996) Cancer incidence near municipal solid
waste incinerators in Great Britain. Brit. J Cancer, 73, 702- 710
Some rebuttal to DEAT's arguments
Internationally there is an increase in banning and moratoria on
incineration (see attached).
The cement industry's carbon dioxide emission from coal is 40%. If they replace
all the coal it would result in a 0.4% saving of SA greenhouse gases. They will
never be able to substitute all their coal usage, so the fraction of 0.4%. Even
when burning waste you will have some carbon dioxide so figures are minimal.
Which international NGO is agreeing to this? It is only be WWF who agrees and
they have been challenged on this practice. They receive funding from Lafarge
Cement.
Gauteng is sitting with a waste crisis, not because KwaZulu-Natal is sending
the anatomical waste to Gauteng, but rather because private companies import
medical waste from Limpopo, North West and Mpumalanga Provinces and they cannot
manage the volumes. When Gauteng agreed to incineration through it's policy
process it became a area that 'attracted waste'.
It will cost society R140 Billion Rand - the waste industry will not pick it up
because this is what externalities are - it is the cost to society.
There is only one consultant pushing co-generation internationally and DEAT has
used him. They have not gone for a neutral party on this.
There was no consultation with community people living next to cement kilns,
despite DEAT and their consultants visiting the management of the industry.
They now want to speak to the community after their information and decisions
are nearly finalized. Their research should have departed from the experience
of local community people and peoples' health status in these areas. They
visited each plant for two hours and based upon this, made a decision to allow
for the burning of waste.
In Norway the only option for hazardous waste is cement kiln incineration.
Waste production has increased over the years rather than decreased.
The DEAT does not know how much waste is being produced, by whom, and what
types, thus they cannot make such a far reaching decision such as incineration.
The two studies that inform this were done in 1992 and 1997, and they
contradict each other. No study was done in the last decade.
DEAT does not know how many medical waste incinerators there are, how many are
permitted or not permitted.
Used ground up tyres can be used in road construction. Improves strength of
material.
Co-generation is not dependent on burning waste, but on improving energy
efficiency in industry such as Sasol, the petrochemical industry and steel
mills.
Pushing the incineration of waste is going to result in the privatization of
waste services because municipalities do not have the skill to manage and operate
incinerators
Incineration does not create jobs, but actually decreases jobs, because
recycling becomes secondary, and recycling creates more jobs than incineration,
up and down stream.
We have raised our concerns with the Public Protector
We have ignored the commitments in the Polokwane Declaration 2001.