legislative compliance

Legislative Framework

Waste managers in the public and private sectors are feeling the impact of new and more demanding environmental legislation in South Africa, particularly in light of potentially severe financial implications and a scarcity of technical expertise. Within this context, EnviroServ Treatment and Disposal Solutions is a valuable partner in helping clients achieve legally complaint, cost-effective and safe waste disposal.

South Africa has an excellent reputation for hazardous waste management, with our Minimum Requirements  being among the most stringent in the world. This guideline document is currently being phased out and replaced with the now promulgated Waste Classification and Management Regulations as published in the Government Gazette of 23 August 2013. One of the most significant impacts of these Regulations is the move away from landfill sites that carried the generic descriptions of “hazardous waste landfill site” or “general waste landfill site” to more advanced thinking where landfill sites are engineered and ranked to contain different levels of risk materials (waste) and hence control the risk to the aquatic environment. This new way of thinking accepts that waste disposed to landfill always carries the potential risk of contamination of the aquatic environment (e.g. groundwater) and that waste needs to be evaluated such that a suitably engineered landfill site that matches the risk profile of the waste is the chosen final destination. This has consequently resulted in four (4) new design standards for landfill sites being promulgated as part of the Waste Regulations by the Department of Water Affairs (DWA). These then range from a Class D design for inert wastes (typically material such as builders rubble), to a new Class A design for high risk level wastes (i.e. wastes that have a high potential to contaminate the environment). These new design standards will gradually be implemented as the older design “hazardous waste landfill sites” (also known as H:H and H:h landfill sites under Minimum Requirements) fill their old waste disposal cells and replace them with new landfill cells. In similar vein, the older “general waste landfill sites” (known as G:L:B+ / G:M:B+ / G:L:B- / etc) will need to decide what level of new landfill cell they will construct when the older cells require replacement. This could range from a Class B design, viewed as equivalent but better designed than the old G:L:B+ design, to the new lower cost Class C (also equivalent but better than G:L:B+). It is interesting to note that the old G:L:B- design is now viewed as only good enough for inert waste as in future the new Class D design is the designated design for such wastes. Municipal landfill sites will be required to replace all of their older cells with the new Class C design going forward.

EnviroServ currently owns and operates five technologically advanced disposal sites, including the Class A (H:H equivalent) Holfontein site; the largest of its kind in southern Africa. All our Class A facilities nationwide are designed by top civil engineers to handle all types of liquid and solid waste and are managed according to accepted international standards.

Hazardous waste management

The recent slew of environmental legislation in South Africa is clear evidence that, much as in other parts of the world, the South African Government intends to move waste management up the well-known waste hierarchy and away from landfill disposal as a final solution. This can clearly be seen in the Waste Regulations and their associated Norms and Standards where there are increasing prohibitions being placed on wastes that should preferably be reduced, re-used, recycled or recovered before being disposed to landfill. These prohibitions are summarized in Table 1 below but with the clear acknowledgement that the years indicated are as of the publication date ie. 23 August 2013.

WASTE PROHIBITED OR RESTRICTED IN TERMS OF DISPOSAL


COMPLIANCE

TIMEFRAME

(From 23 Aug. 2013)

Reclaimable or recyclable used lubricating mineral oils, as well as oil filters, but excluding other oil-containing wastes.

Four (4) years

Reclaimable or recyclable used or spent solvents.

Five (5) years

Waste Electric and Electronic Equipment (WEEE) – Lights.

Three (3) years

Waste Electric and Electronic Equipment (WEEE) – Other.

Eight (8) years

Waste tyres: Whole.

Immediate

Waste tyres: Quartered.

Five (5) years

Liquid waste:

 

  • Waste which has an angle of repose of less than 5º, or becomes free-flowing at or below 60°C or when it is transported, or is not generally capable of being picked up by a spade or shovel; or

 

  • Waste with a moisture content of  40% or that liberates moisture under pressure in landfill conditions, and which has not been stabilised by treatment.

Six (6) years

Hazardous waste with a calorific value of:

 

  • 25 MJ/kg

Four (4) years

  • 20 MJ/kg

Six (6) years

  • 10 MJ/kg

Twelve (12) years

  • 6% TOC

Fifteen (15) years

Brine or waste with a high salt content (TDS  5%), and an LC concentration for TDS of more than
the LCT2 value prescribed for TDS.

Eight (8) years

Disposal of garden waste:

 

  • 25% diversion from baseline of separated garden waste.

Five (5) years

  • 50% diversion from baseline of separated garden waste.

Ten (10) years

 

To ensure that we can continue to provide suitable waste management solutions to our existing as well as future customers, EnviroServ has spent considerable time and effort in identifying solutions that will be able to replace landfill disposal as and when required.