Amendments to the National Environmental Waste Management Act are set to change the waste classification and disposal landscape in South Africa drastically through a new set of new waste classification and management regulations.
Promulgated on 23 August 2013, these regulations took effect on 1 August this year and prescribe two sets of national norms and standards to dictate the assessment and disposal of, among others, hazardous waste including discarded lamps.
The implication for the lighting industry is essentially that spent lamps (including those containing mercury) may no longer be disposed to landfill and that two sets of national norms and standards now require and regulate the assessment and disposal of waste to landfill respectively.
These norms and standards distinguish between and define “waste generators”, “waste managers” and “waste transporters”; regulate waste classification and management within set timeframes, and prescribe requirements for landfill disposal.
Addressing a technical meeting hosted by the IESSA Johannesburg Branch on 28 July 2016, Pravashen Naidoo, MD of lamp recycling company Ewaste Africa, said the norms and standards further impose on lamp manufacturers and importers the onus to ensure that the waste they produce can be reused, recovered, recycled or treated.
He said the standards “seek to facilitate a waste management hierarchy central to the National Waste Management Strategy” and that they present a “total mind-shift for waste management in its entirety”.
But is our lighting industry ready for this?
In an article published by Engineering News shortly after the amendments were promulgated, Liezl Sterne, a health, safety and environmental legal practitioner at GreenGain Consulting, advises companies to “remain informed of the constant amendments to existing legislation and new legislation.”
This would require the services of legal or environmental advisers to interpret the obligations and Sterne notes that implementing the management systems needed for compliance requires “in-house capacity”.
Producers will also need the capacity to classify their waste and provide separate storage for it; identify it and analyse its chemical composition; transport and dispose of it, and to keep extensive records of the process, among others.
They now have six months after generating hazardous waste to classify it either by means of a list of identified wastes provided in the classification and management regulations or in compliance with SANS 10234. Classification to the Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste is no longer valid.
Hazardous waste must be stored separately during the classification process and may only be mixed after classification, and then only if doing so would reduce its environmental impact or render it reusable, recyclable or recoverable.
Waste producers must also provide identification of the substances contained in the waste and conduct sample analysis to determine the total and leachable concentrations for auditing against parameters set in the assessment norms and standards.
Once classified, the waste must be assessed to the Norms and Standards for Assessment for Landfill Disposal issued by the Department of Environmental Management.
Naidoo says waste producers must further ensure that their waste is reused, recycled, recovered, treated or disposed of within 18 months of generation and that they keep updated records of their hazardous waste management for at least five years.
Local industry is accustomed to crushing old lamps and disposing them to landfill, methods considered safe when landfill was the predominant method of waste management.
Waste treatment in this country has, until recently, focused mainly on reducing the risks posed by hazardous waste disposal at landfills. The result is that few alternative waste management options are available to the bulk of waste streams produced locally, including that of lamps.
Stern’s advice for waste producing companies is to align documented procedures with the obligations and to implement systems for proper record keeping. She says it is imperative to communicate changes in procedure to employees and to train them in new waste management protocols.