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WHO WE ARE

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POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CREMATION IN SA. WHO WE ARE. REPRESENTING ENVIROCIN PET CREMATORIUM > EST. 1996 > 35 JOBS REPRESENTING SA ASSOC. OF COMPANION ANIMAL CREMATORIES

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POTENTIAL & UNINTENDED CONSEQUENCES OF S21 LISTED ACTIVITIES & ASSOCIATED EMISSION LIMITS FOR PET CREMATION IN SA

who we are
WHO WE ARE
  • REPRESENTING ENVIROCIN PET CREMATORIUM > EST. 1996 > 35 JOBS
  • REPRESENTING SA ASSOC. OF COMPANION ANIMAL CREMATORIES
  • CREMATE ONLY ANIMAL BODIES > PREVIOUSLY LANDFILLED > HAZARDOUS!
  • 1 IN 3 PETS CREMATED ARE WELFARE PETS FROM SPCA’s etc.
historical snapshot
HISTORICAL SNAPSHOT
  • ORIGINALLY INCLUDED IN CATEGORY 8: DISPOSAL OF HAZARDOUS & GENERAL WASTE 31 MARCH 2010
  • COMMENTED 20 AUGUST 2009
  • MEETING WITH MAZWI LUSHABA 2010
  • COMMENTED 30 JULY 2010
  • COMMENTED 30 JANUARY 2012
  • S21 AMENDMENT 27 FEBRUARY 2012
  • S21 AMENDMENT 23 NOVEMBER 2012
  • COMMENTED 23 DECEMBER 2012
main concerns requests
MAIN CONCERNS & REQUESTS
  • SEPARATION FROM CATEGORY 8: HAZ/GEN
  • CREATION OF CATEGORY FOR COMPANION ANIMAL CREMATORIA
  • CAPACITY THRESHOLD OF 10 TONNES PER DAY HOMOGENOUS ANIMAL MATTER (Directive 2000/76/EC of European Parliament)
  • REVIEW OF BI-ANNUAL TESTING REQ. > CONC VS VOLUME
  • SEEK CLARITY ON “VETERINARY WASTE”
  • THOUGHTFUL REVIEW OF EMISSIONS LIMITS
  • 3% O2 vs 10%?
research data
RESEARCH & DATA
  • DETRIMENTAL EFFECT ON ENVIRONMENT?
  • WSP ENVIRONMENTAL & WNWN TECHNOLOGIES INDEPENDENT STUDIES
  • COST OF WET & DRY SCRUBBERS PROHIBITIVE
  • INTERNATIONAL > LESS RESTRICTIVE (WNWN)
  • 850°C & 1100°C PRIMARY & SECONDARY (US)
  • EPA INFO > “EMISSIONS FROM PC’S VERY LOW WHEN COMPARED WITH OTHER SOLID WASTE COMBUSTION UNITS”
  • EPA > “ADVERSE IMPACTS ASSOCIATED WITH REGULATION OF PC’s OUTWEIGHS BENEFITS OF REGULATION THEREFORE NOT INCLUDED IN OSWI”
  • WSP > DISPERSION MODELLING > “DO NOT POSE A CONCERN TO HUMAN HEALTH”
unintended consequences
UNINTENDED CONSEQUENCES
  • PETS TO LANDFILL > ZINGISA SMALE
  • WELFARE ANIMALS TO LANDFILL
  • HUMAN RIGHTS/ENVIRONMENTAL ISSUE
  • NON-COMPLIANCE & ASSOCIATED PENALTIES
  • JOB LOSSES & UNEMPLOYMENT
  • PET OWNER UPROAR
  • HORSES
  • INHIBITING GROWTH & EXPANSION
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