How to Manage Hazardous Wastes When Disposal Facilities Are AWOL

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Effective and responsible management of solid wastes is one of the most challenging issues faced by companies operating in the developing world, as discussed in a previous blog post – Garage, Garbage Everywhere – A Primer on Solid Waste Management.  As a result, the issue of hazardous waste management is near the top of the list of concerns of many HSE managers.  For instance, last year on a site visit to an oil and gas services company in the middle east, the HSE Manager raised the following issue with me: “We want to manage our hazardous wastes responsibly, but there are no local disposal facilities available!  What can I do? “

Individuals responsible for hazardous waste management are well aware that effective management of these wastes is a challenge even when working in developed countries with well-established regulatory regimes and local waste disposal infrastructure.  Imagine then the challenge faced by the HSE professional in the developing world, where there are either no laws or at best ambiguous laws and regulations, no local municipal or industrial waste disposal facilities (other than uncontrolled or poorly controlled dumps), and a lack of funding to afford building such facilities!  This situation is not at all unusual, and based on my experience this is the norm in most developing countries.

In this blog post I will explore this issue.  I’ll start by making sure we all understand what constitutes hazardous waste, overview hazardous waste management plans, explore issues related to corporate liability, public safety and environmental protection, and I’ll then try to pull this together into some concrete suggestions to help out the beleaguered HSE manager.

What is Hazardous Waste?

The first step in effectively managing this issue is to fully understand what is meant by hazardous waste.  This is not a trivial issue.  There are many “grey areas”, and a surprising number of HSE professionals that I meet do not truly understand which of their wastes are hazardous or non-hazardous.  The lack of understanding has multiple reasons, e.g., lack of clarify in local regulations, environmental duties imposed on the safety manager/personnel with no formal training in environmental/waste management (see a previous blog post –  H&S, OHS, HSE, HSSE, HSSEQ, HSSEQ/CSR … Alphabet Soupization – for more discussion of this issue), etc.

The definition of hazardous waste provided in the Basel Agreement is a good place to start the discussion of “what is hazardous waste”.  The Basel Agreement is one of the most successful international environmental agreements ever developed and controls the transboundary movement of hazardous wastes and their disposal.  180 countries are party to this agreement; the US is a notable exception along with two Asian countries – East Timor and Tajikistan.  So if you work in Asia (or most other countries) you should be aware of this Agreement and these key definitions:

Waste –  defined as “substances or objects which are disposed of or are intended to be disposed of or are required to be disposed of by the provisions of national law”.

Disposal – very specifically defined in 15 separate categories for waste “which do not lead to the possibility of resource recovery, recycling, reclamation, direct re-use or alternative uses”, e.g., land treatment, deep injection, landfills, releases, incineration, storage, etc.   And, there are 13 specific categories of operations “which may lead to resource recovery, recycling, reclamation, direct re-use or alternative uses”, e.g., use as a fuel (other than incineration, solvent reclamation, recovery of components, used oil refining, etc.

Hazardous Waste –  for a waste to be classified as hazardous under the Basel Agreement, it must both (1) within the category of wastes listed in Annex I of the Convention and (2) exhibit one of the hazardous characteristics contained in Annex III (possess a characteristic such as being explosive, flammable, toxic, or corrosive).  A waste may fall under the scope of the Convention is if it is defined as or considered to be a hazardous waste under the laws of either the exporting country, the importing country, or any of the countries of transit.  This specifically excludes radioactive waste and normal wastes from operation or ships.

Most developing countries have adapted these definitions (or ones very similar to these) as part of their national legislation.  In general, if you work in a developing country and follow the Basel Convention definition for hazardous waste, then you will almost certainly also comply with your country’s local requirements.  Of course it would also be prudent of you to review the legislation and regulation in your country of operation.

Hazardous Waste Management Plan

If your facility generates hazardous waste and you are serious about managing this issue, then regardless of where you operate you need a hazardous waste management plan.  I am not going to discuss the hazardous waste management plan in any detail as there are lots of resources on the internet to help you develop one.   IFC’s Waste Management Guidelines are a decent starting point, and include the following main items:

  1. Identify your waste streams, including types and volumes
  2. Identify local requirements – for that you may need an HSE Register
  3. Figure out storage requirements, which will depend on types, volumes and legal requirements
  4. Identify collection and disposal requirements
  5. Documentation, including waste manifests

In the remainder of this post I will focus on is the fourth item on this list – collection and disposal requirements.  And more specifically, I will discuss options for how to handle these wastes when there are no local disposal options available.

What Are the Issues?

There are multiple issues for a site that is generating wastes without proper local disposal facilities.  For hazardous wastes, these issues are many times greater than for typical industrial wastes.  Some of the issues to consider include:

Corporate Liability

Regardless of whether you are following local regulations and are using a government-approved transport company and disposal site, be fully aware that you may be held liable by the local authorities at some point in the future in the event of an incident. This could range from an accidental release/spill from the transport truck, intentional dumping in open areas, releases of toxicants from the disposal site, etc..   Lawyers may argue about the transfer of liability ad nauseam.  But, I strongly suggest that you do not assume that you are protected against liability simply by following local regulations.  In particular, multinational/international companies that operate in developing countries are typically held to a higher/different standard from local companies and are often perceived as an easier target to go after in such events than the local contractors.  Be aware of this – audit your transport contractor, visit the disposal facility and make sure you know where your waste is going once it leaves your site. I guarantee that many of you will be surprised (and not in a pleasant manner).

Public Health

A typical feature of unregulated dumps (and even regulated ones) in many developing countries is the proximity of the dump to nearby residences. In many cases, these residences are occupied by garbage pickers, who spend their days picking through the waste looking to salvage anything of value (and often also with kids, dogs, chickens, etc.).  Needless to say, dumping of hazardous waste at such a site can lead to direct exposure by these vulnerable groups and cause significant short and long-term health impacts and fire/explosion hazards.

Environmental 

One of the main issues with a garbage dump is that runoff of water from the dump drains into nearby lands and leachate generated from rainwater percolating through the dump and infiltrates into the underlying groundwater.  Toxic chemicals that are released in this manner can move offsite and affect environment and people living far from the dump.

Help!  What Can I Do?

Hopefully you are convinced that sending hazardous waste to a dump is perhaps not the most responsible management solution, even if this is the only one available in the area of your operation.  This is of course easy to say, but, we do live in the real world so if that is not the solution then what is?

As a preface, is important to recognize is that every facility that generates hazardous waste has unique features that need to be consider, including location,  relations with local stakeholders, economic considerations, corporate management support, local regulatory needs, technical capabilities, etc.  In short, there is no one-size-fits-all solution to this issue.   With that in mind, here are some options to consider when you do not have a proper local hazardous waste disposal option; one or more may be appropriate at any particular facility.  This is not an all-inclusive list and I am sure that many readers will have other solutions that they have found to be effective.

Prevention and Minimizing the Generation of Hazardous Wastes

This is an obvious first step for all waste management programs, both for hazardous and non-hazardous wastes, and can provide multiple benefits including lower material and waste management costs, more efficient production, reduced pollution, etc.  This will, however, take some time and effort to understand and recognize where wastes can be minimized and to implement them in your operation.  Some areas for consideration include1 2 :

  • improving operating procedures to efficiently use material and avoid spills or cross contamination of waste streams
  • substitution of nonhazardous or less hazardous material for hazardous materials
  • process changes that reduce hazardous materials used and reduce waste generated
  • product redesign to avoid using hazardous materials that generate wastes

This is obviously not possible at all facilities and will only cover certain waste streams, but where it can be done it is most helpful as part of an overall integrated cleaner production approach.

Recycling, Re-Use, Sell, Return to Vendor

Some hazardous wastes can be recycled, reused or returned to vendors for disposal3.  The list can be quite exhaustive and includes for instance lead batteries, oily wastes, catalysts, unused/out-of-spec chemicals, empty containers, etc.  You will need to work with your suppliers and other parties to sort out what is feasible in the area in which you operate.

Local Incinerators

Incineration, if done properly, is a tried and proven method for safe and final disposal of certain hazardous wastes4.  Of course the caveat here is that if done improperly (e.g., low temperatures or with inappropriate wastes), then it is not at all effective and can lead to other problems.   While special hazardous waste incinerators are not available in most developing countries, cement kilns may be available and can be an effective for incineration; indeed, for high caloric value wastes, this can serve as an alternative fuel for the kiln.  There are pros and cons for this technology and a program for hazardous waste disposal in kilns needs to be carefully planned and obviously requires the cooperation of regulators and cement kiln operators.   But, for those with operations that generate significant hazardous wastes appropriate for a cement kiln (e.g., oil field wastes), this may be a disposal option that is worth exploring.

On-Site Disposal

Depending on the local regulations, there may be options for on-site disposal of hazardous waste5.   On-site disposal will require qualified staff and specialized treatment and storage facilities.  Neutralization, wastewater treatment, mobile incineration, containment, monitoring and landfill operations, and other forms of treatment and management processes may be needed for on-site disposal.  While these can be effective, such a program is simply too complex and expensive for most companies to consider.    As such, this would only be an option for the largest and most sophisticated organizations and not practicable at most facilities.

Time and Storage

If you happen to operate in an area where there are plans to build a hazardous waste disposal facility, then depending upon the amount of wastes generated you may consider storing wastes on a long-term basis pending opening of that facility (providing your local regulations permit long-term storage).   This will of course depend on the volumes of waste, availability of land, and the size of storage facility you will require.    Such a storage facility needs to be properly constructed, with adequate protection from elements, runoff control, stabilization of certain wastes, segregation, secondary containment, etc.

Out-of-Country Disposal

For some wastes, out-of-country disposal is an option.  For that you will need to work with your local regulatory authority, transport company and ensure that the disposal is done in accordance with the Basel Agreement.  This can be challenging and expensive so is typically used only in certain situations.

Follow the Local Practice

When all else fails, you may be forced to dispose of your hazardous waste according to the local regulations, even if that means using ill-qualified and non-reputable transport companies and dumps.  In this case, make all attempts to stabilize and contain the wastes to prevent injury to workers, people at the dump and releases to the environment.   This may include for instance neutralization of acids and bases (make sure you know what you are doing!), containment of mobile wastes in concrete, washing oil rags to minimize fire hazards, removal of sharp objects, etc.   Before signing off these wastes to the disposal company, remember that they may end up in contact with children and garbage pickers so take the time to do as much as you can to protect these vulnerable groups from incidental exposure to the wastes.

I trust this is useful in some small manner for those with the challenging job of managing hazardous wastes in developing countries.  Please share your insights in the comments sections below.

Thanks for reading.  Keep safe.  Be healthy.  Respect your environment.

I hope that you will bookmark the blog, share it with your colleagues and visit the blog frequently because you find it informative and helpful.  I value your feedback and suggestions for future topics.

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Next Week’s Blog Topic:  Five of the Worst Mistakes (and Best Lessons) of My HSE Career!

Photo Credits: Toxic waste image courtesy of Andreas Levers at Freeimages.com

Randall D. Shaw, Ph.D.
Latest posts by Randall D. Shaw, Ph.D. (see all)
  1. http://health.hawaii.gov/shwb/p2/
  2. http://ehs.yale.edu/policies-procedures/chemical-hazardous-waste-minimization-tipsn
  3. http://ehs.yale.edu/policies-procedures/chemical-hazardous-waste-minimization-tips
  4. http://www.ckrc.org/myths-and-facts.shtml
  5. http://www.in.gov/idem/landquality/files/hw_info_treatment_on-site.pdf
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5 Comments

  2. Wow, I knew that hazardous waste would be tricky to deal with, but I didn’t realize how serious the issue is. I can’t believe that unregulated waste dumps could potentially cause a fire or an explosion! It just goes to show important it is for companies to follow the regulations put in place. Thanks for sharing some great information about proper storage and disposal. It was really interesting to read about.

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