Contents

1. REVISED WASTE CLASSIFICATION AND MANAGEMENT SYSTEM FOR SOUTH AFRICA Waste Classification System and Standards for Waste DisposalKZN Stakeholder Workshop 30 July 2010

2. Contents • Revised Waste Classification System (Current vs. New) • Waste Categorisation for Reporting • Standard for Disposal of Waste to Landfill • Standard for Leach Tests & Waste Risk Profiling

3. Revised Waste Classification System

4. Waste Classification Regulation • Classification of waste is a legal requirement • Waste Generators must ensure their waste is correctly classified (not necessarily done self) • Classification in accordance with SANS 10234:2008 – Globally Harmonized System of classification & labelling of chemicals (GHS) • Waste Classification = Establishing i.t.o. SANS 10234 whether (i) a waste is hazardous based on physical, health and environmental hazardous properties (hazard classes), and (ii) the degree or severity of hazard posed (hazard categories) • Minister may require peer review of classification done • ‘Pre-classified’ wastes in Schedule 1 to the Regulations do not require classification

5. Purpose of Classification • First step in waste management to determine whether a waste is hazardous or not • Raises initial ‘red flag’ to inform: • Appropriate consideration of suitable waste management options • Adequate and safe storage and handling • Distinguishes first level of Categorisation (General vs. Hazardous) for reporting to the South African Waste Information System (SAWIS) • Classification does not pre-dispose particular waste management option, e.g. classification as hazardous does not mean the waste cannot be re-used, recycled or recovered

6. Schedule 1: Pre-classified waste

7. SA Waste & Chemicals Classification • NEM: Waste Act (59 of 2008): Definitions & Hazardous waste management • Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste (MRHW); 2nd Ed.1998 (draft 3rd Ed. 2005) • SANS 10228:2006 (Ed.4): Identification & classification of dangerous goods for transport • SANS 10265:1999 (Ed.1 amended 2002): Code of Practice - Classification & labelling of dangerous substances and preparations for sale and handling. • SANS 10234:2008 (Edition 1.1): Globally Harmonized System of classification & labelling of chemicals (GHS). • Supplement to SANS 10234 (Edition 1; Dec. 2008): List of classification and labelling of chemicals in accordance with the Globally Harmonized System (GHS).

8. SA National Standards

9. Minimum Requirements (MRHW) Classification • Based on 4 key steps/principles, similar to Basel Convention and many other waste classification systems: • Identification of the waste or waste stream as ‘probably’ Hazardous (source based). • Testing and analysis to determine the hazardous properties, characteristics and components of a waste. This will confirm whether the waste is Hazardous or not. • Classification in accordance with SANS • 10228: "The Identification and • Classification of Dangerous Substances • And Goods". • Analysis and Hazard Rating of the waste • or its residue, in order to determine the • Hazard Rating and the Requirements • for disposal.

10. MRHW Classification • SANS 10228: Risk to man during transport of dangerous goods • MRHW considers risk to water resources & aquatic environment –therefore expands on Class 6: Toxic & Infectious Substances • US EPA TCLP or Acid Rain leach test procedures

11. Classification (SANS10228), Treatment, Disposal

12. Classification (Hazard Rating) – Toxic / Infectious Substances

13. Hazard Rating • HR determined based on acute toxicity (LD50, LC50, EEC) together with environmental fate (biodegradability, accumulation & persistence) • HR 1: Extreme Hazard, e.g. Hg and PCBs – H:H • HR 2: High Hazard, e.g. Mn and Zn – H:H • HR 3: Moderate Hazard, e.g. Ni and phenol – H:h • HR 4: Low Hazard, e.g. Ethanol – H:h • Non-toxic/Non-hazardous, e.g. domestic waste – G • Toxicity Criteria:

14. EEC & ARL • The Estimated Environmental Concentration (EEC) represents exposure by a hazardous substance in waste should it enter into the environment. The pathway for escape is usually water. The EEC therefore represents exposure in a body of water. [EEC(ppb) = dose(g/ha/month) x 0,66] • LC50: concentration that would kill 50% of aquatic animals tested • “One tenth of LC50 ‘should’ have limited effect on aquatic environment & therefore considered to be concentration at which a substance poses an acceptably low risk to the environment” • 0,1 x LC50 is termed the ‘Acceptable Risk Level’ (ARL).

15. Delisting • The EEC is compared to the ARL to indicate whether aquatic environment will be at risk or not. • When exposure (EEC) falls within ARL, the compound is regarded as lesser or no threat to the environment, and can be ‘Delisted’ from a specific risk group to a lower risk or 'non-risk' group. • The waste does not become non-hazardous, but the associated risk declines to a smaller or even acceptable risk.

16. Key Issues, Needs & Limitations (2005) • Integration with international systems • Concept of hazard vs. risk • Classification vs. risk based approach • Standards set for particular hazard characteristics (flammability, corrosiveness etc.) • Acceptability of total load principle and carrying capacity • Scientific credibility of current classification system • Acceptable risk limits are outdated • Applicability of leach testing (TCLP/ARLP) and methodology for analysis • Delisting procedure – acceptability and procedure

17. SANS 10234:2008 South African National Standard for the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

18. Background - GHS Development in SA • 2002-03: SA participates as pilot country in Global Capacity Building Programme. • Study on implications of implementing GHS & development of implementation strategy concluded Dec. ’03. • Review of legislation & policy. • Revise legislation on classification & distribution of Safety Data Sheets. • Proposed Classification & Labelling of Chemical Substances Regulations under S43 of OHS Act, 1993. • Regulations will be implemented in parallel with Hazardous Chemical Substances Regulations (R.1179 of 1995). • Provision for a three- (substances) & seven-year (mixtures) transitional period: Compliance with National GHS Standard and current national system allowed to facilitate transition at national level and to accommodate international trade requirements. • Most recent – Dangerous Good defined i.t.o. SANS 10234 in revised NEMA EIA Regulations (August, 2010)

19. Differences – SANS 10234 vs. 10228

20. Consideration of SANS 10234 • In the process of evaluating the possibility of replacing SANS 10228 with SANS 10234-GHS as basis for waste classification in SA, to ensure alignment with other systems and apply the most appropriate system, it was concluded that: • It would not be efficient or practical to have different systems for hazardous substances (products) and wastes; and • The GHS was not developed focussed on transport as is the case with SANS 10228, and the additional/expanded hazard criteria related to human health and the environment are appropriate considerations for waste handling, treatment and disposal. • Although at first glance, differences between SANS 10228 and the GHS hazard classes & criteria seem extensive, if the whole waste classification system of the Minimum Requirements is considered, the differences are not significant. • Approach & methodology to hazard classification similar in the GHS & SANS 10228 (same principles).

21. SANS 10234 – GHS Classification System • Based on UN GHS (2nd Ed., 2007) • Classification of hazardous substances and mixtures, including waste, according to Physical, Health & Aquatic Environment Hazards • The system incorporates: • Identification of relevant data on hazards • Review of data to ascertain hazards • Classification as hazardous & degree of hazard • Includes information on: • Classification criteria (incl. tests methods & references to e.g. SANS 10228:2006) • Labelling • Hazard symbols/pictograms • Packaging • Safety Data Sheets (SDS) • SANS10234 Supplement provides GHS Classification of the most commonly used chemicals

22. SANS 10234 Physical Hazard Classes

23. SANS 10234 Physical Hazard Classes

24. SANS 10234 Health Hazard Classes

25. SANS 10234 Hazards to the Aquatic Environment

26. MRHW Classification, Treatment, Disposal

27. MRHW Classification (Hazard Rating) – Toxic / Infectious Substances

28. SANS10234-GHS vs. SANS10228 & MRHW

29. Example: Chronic Environmental Hazard

30. Outcome – Review of Minimum Requirements Classification System • Waste Classification i.t.o. SANS 10234-GHS now required • No more disposal (waste management) focused concepts determining classification, so elimination of: • Hazard Rating (HR 1-4) • Acceptable Risk Level (ARL) • Estimated Environmental Concentration (EEC) • Total Load • Delisting • Leach tests & leachable contaminant concentrations has no connection with classification. Now specific to disposal of waste to landfill, and subject to separate regulation & standard

31. Waste Categorisation for Reporting

32. Objectives • DEA Objectives – • To report on the success of national waste policy in moving waste up the hierarchy from landfilling to reuse, recycling and recovery • Identify the impact of policies and waste management interventions • Identify waste streams requiring further management intervention • To achieve this objective, DEA needs to know – • What waste are currently generated in SA? • How much waste are we generating? • How is the waste currently being managed ? • Can answer questions by generating the following reports: • Tonnages of waste finally treated, recycled, recovered or landfilled • Achieved by waste management facilities reporting under specific waste management category • Reporting on specific waste types managed

33. Waste Categorisation • Identifies waste management facilities that must report • Identifies codes under which the facilities must report • Provides a list of waste types which must be reported on • Identifies waste generators that are required to register • Requirements are implemented through the WIS regulations

34. Who registers?

35. Registration • All waste management facilities are required to register under specific codes and sub-codes • Codes: • R: for recycling and recovery of waste • T: for treatment of waste not for disposal i.e. final treatment • D: for disposal of waste • Sub – codes • R1 - R6 • T1 - T4 • D1 - D5 • All generators of hazardous waste generating in excess of 20kg of hazardous waste/day are required to register and receive a registration number • All major generators of HCRW (i.e. > 20kg/day) are required to register and receive a registration number

36. Waste Management facilities required to register & registration codes

37. Who reports on what?

38. Reporting • All WM facilities identified in the wm codes must report • not all facilities requiring a waste licence will report i.e. waste separators, bulking & transfer facilities – the final handler or user will report i.e. the recycler or recoverer • Reporting is required on three levels • level one – waste classification • Level two – major waste type • Level three – specific waste type • The WM facility must report per waste generator if the generator has a WIS registration number (i.e. if the generator generates in excess of 20kg of hazardous waste per day) • Information will be available from the manifest system which is required in terms of the WC & M regulations

39. Information required to be reported

40. General Waste Reporting Categories

41. Hazardous Waste Reporting Categories

42. Hazardous Waste Reporting Categories

43. Standard for Leach Tests & Waste Risk Profiling

44. Standard for Leach Tests & Waste Risk Profiling • Applicable to hazardous & general waste (with exclusions, e.g. domestic). • Shift from MR approach, where leachable concentration used to calculate EEC, which is compared with ARL to determine maximum amount that can be disposed to landfill, and leachable concentrations informing the Delisting of waste (from hazardous to general). • Now: Classification of waste in terms of SANS 10234 (GHS) – hazardous or not. Informs storage, handling, transport, reporting etc. • No provision for delisting, EEC, ARL etc. • Contaminant concentrations in waste now determine specific requirements for disposal.

45. Approach • Leachable Concentration (LC) and Total Concentration (TC) are compared with three levels of threshold values, which in combination, determines the Risk Profile of the waste. • The Waste Risk Profile reflects degree of potential risk associated with disposal where waste could impact on groundwater. • Risk profiling designates four types (risk levels) of hazardous waste, each with specific landfill design requirements (management linked with the existing Minimum Requirements for Landfill).

46. Terminology • Leachable concentration thresholds = SA Standard Leaching Procedure values = SASLP0, SASLP1 and SASLP2. • Total concentration thresholds = SA Standard Total Concentration values = SASTC0, SASTC1 and SASTC2. • LC = Leachable concentration (mg/l) of a specific contaminant - compared with SASLP threshold values. • TC = Total concentration (mg/kg) of a specific contaminant - compared with SASTC threshold values.

47. Leach Test Methodology • Australian Standard Leaching Procedure (ASLP); based on USEPA TCLP – uses L/S ratio of 20:1 etc. • But, particle size <2.4mm - slightly more conservative than TCLP, and &a basic borate buffer & reagent water for non-putrescible wastes (in addition to standard acetic acid based extractants). • ASLP allows for alternative leaching scenarios, with the leaching solution depending on the waste. • Total Concentration or Specific Contaminant Concentration is determined by standard extraction techniques, e.g. Acid – referred to US EPA SW846 Guidelines • Leachable Concentration by Australian Standard Leaching Procedure (ASLP): • ASLP – essentially the TCLP (pH 5.0 or 2.9) • Water Leach – as for TCLP but replace with reagent water • Tetraborate Buffer - as for TCLP but use a borate buffer pH 9.2

48. Leach Test Methodology • ASLP allows for alternative leaching scenarios, with the leaching solution depending on the waste: • Waste to be disposed with or contain putrescible wastes: Standard TCLP solutions with altered pH 5.0 or pH 2.9 (0.1M acetic acid) depending on acid neutrilisation capacity of waste. • Waste to be co-disposed with non-putrescible material: A basic solution consisting of a 0.1M sodium tetraboratedecahydrate of pH 9.2±0.1 (alkaline test identifies contaminants that are leached at high pH). • Waste that is to be left undisturbed on-site, or dispersed over land without confinement, or non-putrescible material, e.g. mono-disposal scenario: Reagent water solution (also relate to contaminated land assessment; in-situ).

49. SASLP & SASTC Thresholds • Leachable concentration based on DWAF, SANS, WHO & USEPA drinking water standards, muliplied by dilution attenuation factor (DAF) of 50, as Victoria EPA (NSW & USEPA – DAF of 100). • DAF value of 50 for lowest or base level leachable concentration (SASLP0) – on basis of precautionary principle. • SASLP1 = 2 x SASLP0; SASLP2 = 4 x SASLP1. • Represents a conservative assessment of the decrease in risk achieved by the increase in environmental protection provided by landfill construction and landfill operating requirements (Minimum Requirements = factor 5; attenuation due to liner & leachate management). • SASTC values derived from Contaminated land Standards, but consideration given to different risk exposure pathways. • SASLP & SASTC values are aligned with international standards (US, EU, Australia, UK, New Zealand etc.)

50. SASLP & SASTC Thresholds: Inorganics