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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.