Based on the analysis set out in the precedingchapters and the information contained in theStrategy Study Report, a series of recommendationsare set out in this chapter.

9.1 Prevention of hazardous waste

1. A national waste prevention programme withan emphasis on hazardous waste should bedeveloped and implemented. The hazardouswaste Prevention Programme proposed in thisPlan should deal with process waste andproduct waste. This will ensure that bothmanufacturers and consumers become aware ofand responsible for hazardous wastemanagement. The initial emphasis should beon initiatives which will yield the greatestreduction in environmental impact and whichwill maximise environmental benefits.

2. The following targets for the prevention ofhazardous waste should be adopted:a) no increase in hazardous waste disposal

over 1996 quantities – a “standstillscenario”; and

b) elimination of unreported hazardouswaste.

3. A core “Prevention Team” should be establishedto prioritise, implement and manage thePrevention Programme.

4. A mechanism for funding the PreventionProgramme should be established based onapplication of the polluter pays principle.

5. Industrial developments should be consideredin terms of their environmental impacts andthe development of industry with lowhazardous waste generating potential shouldbe a priority.

9.2 Collection of hazardous waste

1. Household hazardous waste should besegregated. Local authorities should plan forand make provision for waste collectionfacilities to householders. Any such service

should be available to other small scalegenerators of hazardous waste.

2. Consideration should be given to: (1) theimposition of producer responsibilityobligations; (2) the operation of deposit andrefund schemes; and (3) the commencement ofother waste collection measures which wouldassist in improved management of unreportedhazardous waste.

3. Information campaigns should be conducted(a) locally, by local authorities as part of theirwaste management planning publicity, and(b) nationally, by ENFO, the Department of theEnvironment and Local Government, etc., toensure the success of collection initiatives andto increase collection rates. These campaignsshould initially focus on household, SME andother unreported hazardous waste.

9.3 Recovery and disposal of hazardouswaste

1. In order to apply the proximity principle andto ensure security of hazardous waste recoveryand disposal outlets, Ireland should seek tobecome self sufficient in hazardous wasterecovery and disposal capacity.

2. The majority of hazardous waste processed offsite in Ireland in 1996 and 1998 was recovered.Continued support may in future be requiredfor the hazardous waste recovery industry toensure that it remains viable. The possibilitiesfor additional state funding should beexplored.

3. At least two engineered cells for the landfilldisposal of hazardous waste should bedeveloped, initially in the south-west andDublin areas. These cells could be constructedadjacent to existing landfill facilities with theobjective of utilising existing infrastructuresuch as site roads, weighbridges and stafffacilities. The prospect of municipal thermaltreatment facilities could be taken into accountin locating and determining the capacity ofhazardous waste landfill disposal facilities.

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9. RECOMMENDATIONS

4. A thermal treatment disposal facility for themanagement of hazardous waste currentlyexported for disposal is required if Ireland is tobecome self sufficient in hazardous wastemanagement. In the event of a facility beingestablished, consideration should be given tothe imposition of import and export restrictionsin relation to the disposal of hazardous waste.

5. An inventory of PCB holdings is required tosatisfy Council Directive 96/59/EC on thedisposal of polychlorinated biphenyls andpolychlorinated terphenyls (PCB/PCT). The EPAshould consider the provision of technicalinformation and guidance to holders of suchholdings and equipment.

9.4 Hazardous waste disposal sites

1. Local authorities should compile ‘Section 26registers’ based on the methodology outlinedin this Plan.

2. Each site in a ‘Section 26 register’ should besubjected to a preliminary risk assessment andcategorisation (see chapter 7.5).

3. Statutory guidance on the identification ofappropriate remediation strategies should bedeveloped by the EPA.

9.5 Resources and funding

1. Resources should be made available for thedevelopment and implementation of thePrevention Programme with an initial focus onthe establishment of a prevention team and alonger term focus on the making of voluntaryagreements, or the use of other instruments,for the prevention of hazardous waste.

2. Resources should be made available for theprovision of improved hazardous wastecollection, recovery and disposal facilities andservices.

9.6 Implementation of the NationalHazardous Waste Management Plan

1. An Implementation Committee should co-ordinate implementation of this Plan. Themembership of the committee could be made

up of representatives of organisations with astatutory responsibility for the management ofwaste and of producer organisations.

2. The Implementation Committee shouldperiodically report on implementation of thePlan. All statutory bodies responsible for theimplementation of the Plan should reportprogress to the Committee on an annual basis.

3. A technical working group should beestablished to consider the prescription ofhazardous wastes in Ireland as provided for inthe Waste Management Act, 1996.

9.7 Priorities 2001-2006

1. The establishment of an ImplementationCommittee by the Department of theEnvironment and Local Government. Thiscommittee would be responsible for guidingthe overall implementation of the Plan.

2. The establishment of a Prevention Team toimplement the Prevention Programme. This‘Team’ would be responsible for thedevelopment of the Programme, for the settingof priorities within the Programme itself andfor their initiation.

3. The identification and elimination ofunreported hazardous waste to prevent itsuncontrolled disposal and resultant emissionsto the environment.

4. The identification, preliminary evaluation andprioritisation of sites at which hazardous wastedisposal has taken place and the implementationof remedial works at priority sites.

5. Establishment of an improved collectioninfrastructure for hazardous household,agricultural and SME wastes.

6. The allocation of financial and technicalassistance for the development of facilities forthe recovery and disposal of hazardous wastewhere existing capacity is unsatisfactory.

7. The development of hazardous waste landfillcapacity and thermal treatment for hazardouswastes requiring disposal to achieve selfsufficiency and reduce our reliance on export.

8. Improved public awareness of the impacts ofhazardous wastes.

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9. Build on on-going prevention, research anddemonstration initiatives – for example, theCleaner Production Pilot DemonstrationProgramme.

9.8 LLoonnggeerr tteerrmm pprriioorriittiieess bbeeyyoonndd tthhee ffiivveeyyeeaarr rreevviieeww ppeerriioodd ooff tthhee PPllaann

1. The achievement of self sufficiency inhazardous waste management.

2. No increase in hazardous waste disposed ofover 1996 quantities.

3. The qualitative reduction (i.e. reduction in thedegree of hazard) of hazardous waste.

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