EnviroServ comments - NWMS - May 2012 1

Comments on the National Waste

Management Strategy (Nov. 2011)

Johan SchoonraadTechnical DirectorEnviroServ (TDS)

EnviroServ comments - NWMS - May 2012 2

Definition of “Waste”• Definition is a cornerstone to the Waste Act

• Flawed definition in the Act impacts all subsequent Strategies, Regulations, Guidelines, etc

• Hinders the implementation of the objectives of the Act

• Many “waste” materials cannot be removed due to the use of the word “and” instead of “or” in the wording:

“…(ii) any portion of waste, once re-used, recycled and recovered, ceases to be waste”.

• Not always possible to implement all three (3) processes

• Should read:“…(ii) any portion of waste, once re-used, recycled or recovered, ceases

to be waste”.

• Now resolved ?

EnviroServ comments - NWMS - May 2012 3

Definition of “By-product”• According to the Waste Act:

‘‘by-product’’ means a substance that is produced as part of a process that is primarily intended to produce another substance or product and that has the characteristics of an equivalent virgin product or material;

• In many cases there is no “equivalent virgin product or material”

• Material automatically becomes a “waste”

• Requires a Basic Assessment or EIA and waste management licence to process

• Propose that it should read:‘‘by-product’’ means a substance that is produced as part of a process

that is primarily intended to produce another substance or product

EnviroServ comments - NWMS - May 2012 4

Thermal Waste Treatment

• NWMS states that “disposal Guidelines will also be developed for thermal waste treatment”

(Page 25 of 74 – 3rd last bullet point)

• EnviroServ’s understanding that these have already been developed as the NATIONAL POLICY ON THERMAL TREATMENT OF GENERAL AND HAZARDOUS WASTE as published in the Government Gazette No.32439 of 24 July 2009.

• Emission standards as Section 21 of the Act published

EnviroServ comments - NWMS - May 2012 5

Mechanisms for developing standards Pg 41 of 74 – Paragraph 3.3.1

• 1st paragraph of the NWMS states “The development of complex technical standards that must be scientifically exact will use the standard setting procedure of the South African Technical Infrastructure (SATI), which falls under the South African Bureau of Standards (SABS)”.

• Framework for the Management of Contaminated Land?

• Waste Classification and Management Regulations?