NATIONAL WASTE MANAGEMENT STRATEGIES AND ACTION PLANS SOUTH AFRICA

Action Plan Development PHASE

EXECUTIVE SUMMARY *

table of contents *

List of Abbreviations *

1. Background *

2. Analysis *

3. Logical Framework Analysis *

4 Implementation *

Annexures *

A number of high priority short-term initiatives relating to waste treatment and disposal were identified in the National Waste Management Strategy Version ‘C’ (June 1999). This Action Plan for Waste Treatment and Disposal was developed to prepare for the implementation of these initiatives, by defining the targets, activities, tasks, responsibilities, timing, control procedures and the results/outputs expected. High priority short-term initiatives relating to the collection and transportation of hazardous waste are also included in this Action Plan.

A number of external factors are identified as critical to the successful implementation of this Action Plan. These include acceptance of the NWMS by government and other stakeholders, allocation of adequate human and financial resources and successful implementation of other Action Plans (i.e. Implementing Instruments, Capacity Building, Integrated Waste Management Planning and Waste Information System, Waste Minimisation and Recycling) developed as part of the NWMS project.

Until recently (1997), waste management was not regarded as a national priority issue in South Africa. The waste management that took place focused mainly on waste disposal and was reactive in that it addressed needs as they occurred. Holistic, integrated waste management planning was rarely, if ever, undertaken. The low priority that was historically accorded to waste management has resulted in waste impacting detrimentally on the South African environment and on human health.

Section 24 of the Constitution of the Republic of South Africa (Act 108 of 1996) states that the people of South Africa have a right to an environment that is not detrimental to human health, and imposes a duty on the state to promulgate legislation and to implement policies to ensure that this right is upheld. To date, a number of steps have been taken to ensure this environmental right, including the publication of the Environmental Management Policy for South Africa (1998), the publication of the Draft White Paper on Integrated Pollution and Waste Management (IP&WM) (Notice 1686 of 1998), the promulgation of the National Water Act (NWA) (Act 36 of 1998) and National Environmental Management Act (NEMA) (Act 107 of 1998), and the development of a National Waste Management Strategy (NWMS) (1999), of which this Action Plan is part.

The project for the development of a National Waste Management Strategy for South Africa was initiated during 1997 by the Department of Water Affairs and Forestry (DWAF) and the Department of Environmental Affairs and Tourism (DEAT), with financial support from the Danish Co-operation for Environment and Development (DANCED). The overall objective of the NWMS is to reduce the generation and environmental impact of all forms of waste and to ensure that the health of the people and the quality of the environmental resources are no longer affected by uncontrolled and uncoordinated waste management. In line with the IP&WM approach, the NWMS addresses all elements in the waste management hierarchy.

The NWMS project comprises four phases:

Phase I, the Inception Phase (completed in December 1997), involved detailed planning for the project in consultation with stakeholders.

Phase II, the Situation/Baseline Analysis Phase (completed in May 1998) identified waste issues, problems and needs and synthesised the findings into an integrated situation/baseline analysis which was workshopped with stakeholders to identify the waste management needs and issues to be addressed in the strategy formulation phase.

Phase III, the Strategy Formulation Phase, commenced immediately after completion of the Situation/Baseline Analysis Phase, with debate of the key issues identified during the preceding phase, and development of a broad range of strategic options and scenarios. The Draft NWMS, Version A document was compiled based on these inputs and direction from the Project Steering Committee (PSC), and was workshopped with stakeholders in November 1998. At the request of workshop attendees and the PSC, the Draft NWMS, Version B document was compiled, and issued for stakeholder comment over the period mid-December 1998 to mid-February 1999. Input received was compiled in a Stakeholder Analysis Report, which was incorporated in the final NWMS Version C that has been approved by the PSC.

The National Waste Management Strategy (NWMS) represents the vision of the Department of Environment and Tourism (DEAT) and the Department of Water Affairs and Forestry (DWAF) for an integrated approach to waste management. Consultation with a wide range of stakeholders (i.e. other government departments, NGOs, CBOs, business, labour, and industry and mining) has identified the problems, needs and issues that have been addressed in this long-term strategic plan.

The NWMS has translated government’s policy on integrated waste management as set out in the Draft White Paper on Integrated Pollution and Waste Management for South Africa and within the framework of existing legislation. At present this draft white paper is a guideline document until formal Cabinet approval is received. Development of the Action Plans has highlighted legislative requirements that will be reviewed within the ongoing DEAT Law Reform Process.

The NWMS (and Action Plans) represent a first generation plan for addressing South Africa’s waste management problems that will be continually updated to meet practical realities. The duties, roles and responsibilities outlined in the Strategy are therefore an initial proposal, which will be discussed, clarified and agreed to during inter-governmental discussions. The allocated responsibilities will be amended where necessary and implemented within the context of co-operative governance with the support of the role players. Cognisance will be taken of the legal mandates of the relevant government departments. A phased approach to implementation of the NWMS is envisaged to integrate the waste management functions to ensure an efficient and effective system that meets the requirements of all stakeholders.

The ultimate aim of the NWMS is to implement a co-ordinated integrated waste management system to ensure ‘cradle to grave’ management of waste. Stakeholders have identified the elimination of the duplication and overlap of waste management regulatory activities as a key requirement. To meet this objective will require the commitment, support and co-operation of all stakeholders in the implementation of the NWMS and the associated Action Plans.

Phase IV, Action Plan Development Phase. The process of developing Action Plans to implement the priority strategic initiatives identified in the draft NWMS commenced in early 1999. In order to develop a practical and implementable strategy, the priority initiatives have been categorised into short, medium and long-term priorities. Stakeholders have in principle accepted a number of initiatives that require urgent attention.

Of these priority initiatives, implementation of integrated waste management planning, provision of general waste collection services to previously unserviced areas and the development and implementation of the Waste Information System (WIS) were identified as high priority. Draft Action Plans were therefore developed for Integrated Waste Management Planning, General Waste Collection, and the Waste Information System, as well as an Interim Project Plan for Implementing Instruments. During the development of each draft Action Plan, due cognisance was taken of all stakeholder comments compiled in the Analysis Report (PMG 112). Action Plans, Set I for implementation of the short-term high priority strategic initiatives for Integrated Waste Management Planning, the Waste Information System, General Waste Collection, and Implementing Instruments were developed between January and April 1999.

Action Plans, Set II for the remaining elements of integrated waste management, namely Waste Minimisation and Recycling and Waste Treatment and Disposal will be developed over the period May to September 1999. At the same time, the Interim Project Plan on Implementing Instruments was updated and the Action Plan for Capacity Building has been finalised. The purpose of the Action Plans is to assist the relevant spheres of government by detailing the main activities that will have to be undertaken to successfully implement the priority initiatives of the NWMS; the Action Plans are thus procedural in nature.

In the NWMS, Version C, ‘short-term’ was defined as the period 1999 to 2002, ‘medium-term’ as 2003 to 2006 and ‘long-term’ as 2007 to 2010. However, during the development of the Action Plans, it became clear that the implementation of the short-term Action Plans could not begin before July 1999, and there was also uncertainty whether sufficient budgetary provision had been made for implementation in the 1999/2000 budgets. It was therefore decided that, based on the practical situation and suggestions by stakeholders, the short-term Action Plans would cover a more extended period from July 1999 to December 2004, and the dates contained in this Action Plan, with the exception of Section 1.3, were adjusted accordingly. Future medium and long term Action Plans will therefore cover the periods 2005 to 2008 and 2009 to 2012, respectively.

A number of the issues and problems relating to waste treatment and disposal were identified during the Situation/Baseline Analysis Phase of the NWMS, and priority strategic initiatives were therefore developed to address these problems. The objective of this Action Plan is to translate the NWMS short term priority initiatives for Waste Treatment and Disposal into an operational and measurable Action Plan by defining the targets, activities, tasks, responsibilities, timing, control procedures and the results/outputs expected. The short-term priority initiatives, as stated in the draft NWMS Version C, are summarised as follows:

• Waste Treatment: Standards for medical waste incinerator air emissions, as well as classification of all waste treatment facilities, will be reviewed, revised and enforced. A public awareness and waste management education campaign will be introduced to focus on the hazards of medical waste and the legal responsibilities of medical waste generators.
• Waste Disposal: A process will be initiated to register all landfill sites. Plans will be submitted by landfill owners for remediation and/or meeting the DWAF Minimum Requirements. In addition, the permit conditions for those sites currently permitted will be enforced through regular monitoring and auditing. A new permitting process will be initiated for mining and power stations. New hazardous waste disposal sites will be established.

In addition to the above activities, short-term priority initiatives for the collection and transportation of hazardous waste are addressed in this Action Plan.

This Action Plan integrates and co-ordinates waste treatment and disposal with parallel activities in the NWMS to ensure that:

• Regulations (i.e. the legal component) are developed in parallel with the other Action Plans.
• Financial instruments are developed in parallel with the other Action Plans.
• Public/private partnerships are encouraged.
• Sufficient capacity building takes place (the capacity building Action Plan).
• Public awareness campaigns are implemented.

This Action Plan on Waste Treatment and Disposal represents a first generation plan aimed at addressing key issues, needs, problems currently experienced with waste treatment and disposal in South Africa. This document represents the optimum approach to the implementation of the activities of the Action Plan in terms of resource allocation, time schedule and responsibilities. Resource constraints may limit the full implementation of the Action Plan according to the proposed time schedule, thus continual monitoring and adaptation of the Action Plan to meet the demands of the practical situation will be required. As increased resources become available, additional initiatives can be implemented.

The NWMS, and specifically the short-term priority initiatives for waste treatment and disposal, formed the basis for development of this Action Plan. The development commenced with a review of the status quo of waste treatment and disposal in South Africa, as well as the relevant policies and strategies. The Logical Framework Analysis (LFA) approach was used to develop the Action Plan, which entailed an analysis of the problems, the stakeholders in the process and risks to the successful implementation of the Action Plan. The project objectives, outputs, and activities required to achieve the outputs, inputs, assumptions (external factors) and the means of verification were determined and described. Finally, the functions, roles and responsibilities of the implementers and the procedures for evaluating, reviewing and reporting on the implementation of this Action Plan were described.

In future, all waste management functions will be consolidated within DEAT (including the provincial environmental departments (PEDs)) which will be the "lead agent" for the environment, subject to the completion of negotiations between DEAT and other national departments. Recognising that capacity, expertise and financial resources remain limited within DEAT and the PEDs, it is anticipated that a period of five to seven years will be required to build the necessary capacity within DEAT and the PEDs. For this reason, this Action Plan for Waste Treatment and Disposal, which covers a period of five-and-a-half years, focuses on current responsibilities throughout, although reference is made, where appropriate, to possible future responsibilities.

The implementers of this Action Plan should familiarise themselves with the National Waste Management Strategy Documents. The most important information for further development and implementation of the Action Plan for Waste Treatment and Disposal is contained in the following documents:

• National Waste Management Strategy, Version C, 7 June 1999, PMG 130.
• Strategic Options Discussion Document, Synthesis Report, 3 August 1998, PMG 69, including Annexure A – Non Hazardous Waste, PMG 70 and Annexure B – Hazardous and Related Waste, PMG 71.
• Situation/Baseline Analysis Report, Synthesis Report, 30 March 1998, PMG 26.
• Situation/Baseline Analysis Report, Annexure A – Non Hazardous Waste, 27 March 1998, PMG 27 and Annexure B – Hazardous and Related Waste, 27 March 1998, PMG 28.

During the Situation Baseline Analysis Phase of the NWMS, baseline reports were prepared for General (Non-hazardous) and Hazardous and Related Waste, covering, inter alia, waste treatment and disposal. These reports (PMG 26, 27 and 28) contain a comprehensive discussion of the status quo of waste treatment and waste disposal in South Africa. A summary of the key information presented in these reports follows, updated as far as possible to reflect new developments in these fields.

The current approach to general waste treatment in South Africa is typical of a developing country, in that treatment of this waste involves simply a reduction of its volume, e.g. baling or shredding, although some small-scale incineration and composting is practised. The emphasis remains on disposal of general waste by landfill without treatment as the lowest cost disposal option, as landfill airspace is still available in South Africa. The lack of pre-treatment of general waste before disposal is therefore currently not regarded as a problem in South Africa.

Co-disposal of hazardous with general wastes on specially designed landfill sites is common. As in the developed countries, pre-treatment of certain wastes, prior to landfilling, is considered essential, due to the dangers of reaction with other wastes and the landfill liner, as well as potential odour problems and effects on the quality of the leachate. The most common forms of treatment of hazardous waste (other than medical/infectious waste) practised in South Africa are:

• Encapsulation of extreme and high-hazard waste. This technology is high cost and, although it isolates the waste from the environment, it must be classed as storage rather than treatment since the process does not destroy or reduce the toxicity of the waste.
• Chemical, Physical and Biological Treatment of hazardous waste are processes used to reduce the toxicity of the waste before disposal. Limited standards and guidelines are available for these practices.

Household hazardous waste is not usually separated from the general waste stream and treated, but is co-disposed in a General Waste disposal site.

In South Africa incineration of general waste and hazardous waste is not acceptable to many stakeholders due to the poor operation of many existing facilities and non-compliance with the Atmospheric Pollution Prevention Act. The incineration of general waste is not economically feasible in South Africa since its warm climate limits the market for the energy/heat derived from the incineration process. The majority of operating incinerators in South Africa are used for the treatment of infectious medical waste, as stipulated in the Human Tissues Act

The disposal of both general and hazardous waste by landfill is the most cost-effective option. Illegal dumping and the creation of informal landfills (often in the form of burning on open dumps) is a major problem in lower income communities, due to the lack of organised collection of general and hazardous waste and exacerbated by a lack of environmental ethics. Medical waste is often disposed at these sites, and informal salvagers and the general public, especially young children, are at risk of contracting Tetanus, Hepatitis and other diseases from this practice. A related, and very serious problem, is the illegal disposal of hazardous chemical wastes on general waste landfills and open dumps.

In the past, the emphasis of waste management in South Africa has been on waste disposal. Waste disposal, however, has an adverse impact on the environment and public health, particularly in cases where there has been no thorough waste management planning, the landfill has been inappropriately sited and designed and inadequately managed and operated.

Increased environmental awareness during the 1980’s focused attention on landfill sites and a landfill permitting system was consequently developed by DWAF. To establish standards for implementing the landfill permitting system, DWAF also produced the Minimum Requirements documents, including the Minimum Requirements for Waste Disposal by Landfill, the 1^st Edition in September 1994 and the 2^nd edition in September 1998. The main effect of the Minimum Requirements was the improvement of the quality of landfilling throughout the country, due to upgrading and higher environmental standards for landfill sites; on the other hand there was a concomitant increase in the cost of disposal. At present very few landfill sites charge disposal tariffs although this situation will be addressed as a mechanism of cost recovery.

There are a limited number of disposal sites in South Africa, which dispose of hazardous waste in an acceptable and professional manner and in accordance with the Minimum Requirements. Since there are not enough of these facilities, hazardous waste is often transported over long distances, resulting in increased risks of accidents and higher transport costs.

Based on an 85% return, the IPC&WM baseline survey of June 1997 identified 540 operating landfills and 53 future sites in South Africa. It was noted that there could be up to 15 000 unrecorded communal sites in the rural areas. Of the 540 sites recorded, only 115, or 26% were permitted at that time. According to DWAF, there are currently 368 landfills permitted, which represent approximately 60% of the total.

The inappropriate treatment and disposal of mining and coal combustion wastes has often resulted in contamination of water resources by salts, iron and many other trace elements. Acid mine drainage resulting from the oxidation of iron pyrites, as well as the presence of elevated levels of naturally occurring radioactive materials at some mine disposal sites, are of considerable concern. The pollution potential of these wastes is not completely understood and it is essential that appropriate standards are set and guidelines published to control the treatment and disposal of these wastes.

The Consultative National Environmental Policy Process (CONNEPP) resulted in the development of the Environmental Management Policy for South Africa and the promulgation of the National Environmental Management Act (NEMA) (Act 107 of 1998). This Act provides for co-operative environmental governance by establishing principles and procedures for decision making on matters affecting the environment. An important function of NEMA is to serve as an enabling Act for the promulgation of legislation to effectively address integrated environmental (including integrated waste) management.

The over-arching goal of the IP&WM policy is to move from a previously fragmented situation of uncoordinated waste management to that of integrated waste management. The Draft White Paper on Integrated Pollution and Waste Management for South Africa defines government’s approach to the management of waste (i.e. an holistic and integrated management approach extending over the entire waste cycle from cradle to grave, including the generation, storage, collection, transportation, treatment and final disposal of waste).

The IP&WM policy represents a paradigm shift in South Africa’s approach to waste management. Historically, pollution control focused primarily on impact management and remediation of pollution. However, to ensure sustainable development, the focus has recently moved to pollution prevention. In the case of water quality management, as early as 1992 the end-of-pipe control approach was replaced with an approach in line with the waste hierarchy and pollution prevention was prioritised.

The National Waste Management Strategy process was undertaken to ensure that the IP&WM policy is translated into practice. Central to the development of the Strategy for integrated waste management has been:

• The pollution avoidance/prevention and waste minimisation approach that focuses on the source of waste and moves away from "end-of-pipe" solutions.
• The need to extend an acceptable level of waste management services to all communities, and to establish well-designed waste disposal facilities for the appropriate treatment of hazardous waste prior to disposal.

The NWMS strategy follows the waste hierarchy approach (see Figure 1.1), which is an internationally accepted approach to integrated waste management.

Figure 1.1: Steps in Waste Hierarchy

One of the NWMS initiatives is to review existing environmental legislation and associated legislation required to implement the NWMS. This review will highlight:

• Where legislation is replicated.
• Where legislation is deficient with respect to implementation of the initiatives within the NWMS.

The key legislation regulating waste treatment and waste disposal in South Africa is addressed in sections 1.2.2 and 1.2.3.

DEAT has initiated a Law Reform Process to consolidate the currently fragmented pollution and waste legislation into a new Act which will deal in detail with waste treatment and disposal activities. In terms of Section 20 of the Environment Conservation Act (ECA) (Act 73 of 1989), no person may "establish, provide or operate any disposal site without a permit issued by the Minister of Water Affairs and Forestry". Permits are issued subject to certain conditions.

DWAF has developed the Minimum Requirements documents to set environmentally acceptable standards for (i) waste disposal by landfill; (ii) the handling and disposal of hazardous waste; and (iii) water monitoring at waste management facilities. The standards set in the Minimum Requirements are based on a classification system described in the documents. The Minimum Requirements are enforced through the landfill permitting system.

The disposal of waste is identified under Section 21 of the ECA (GN 1182 of 5 September 1997) as an activity "which may have a substantial detrimental effect on the environment". As a result, the Regulations regarding environmental impact reports (GN 1183 of 5 September 1997) are applicable to the disposal of waste, and written authorisation in terms of Section 22 of the ECA must be obtained, usually from the provincial environmental departments, before a waste disposal operation may be undertaken. However, the definition of waste for the purposes of the Environment Conservation Act (GN 1986 of 24 August 1990) excludes wastewater and effluent, building rubble used as fill material, radioactive materials, mining waste and ash resulting from power generation. As a result, disposal of these materials is not subject to the requirements of Section 20 of the ECA.

The responsibility for refuse removal, refuse dumps and solid waste disposal is assigned by the Constitution of South Africa to local government, which is expected to formulate appropriate by-laws for these activities.

The Atmospheric Pollution Prevention Act (APPA) (Act 45 of 1965) controls only the incineration of waste and classifies three types of incineration:

Medical waste incineration was included in the APPA in 1993/1994. Previously these incinerators were under controlled by the local authorities. On implementation of the APPA, emission standards were defined in guidelines based on international experience and taking into consideration the size and number of facilities in South Africa. However, since these emission standards could not be achieved with any of the incinerators in South Africa, government took the following decisions:

1. By December 2001 all existing incinerators must be upgraded or replaced to meet the required two-stage incineration temperatures and residence time.
2. New incinerators, with a capacity of less than 1 000 kg/hour, must operate at the required temperatures and residence time. If the emission standards cannot be met, an acceptable dispersion model may be used to determine whether the incinerator is acceptably located.
3. All incinerators with a capacity of more than 1 000 kg/hour must be fitted with pollution control equipment.

Guidelines were issued for general waste incinerators, but to date the small incinerators operated by local authorities are not controlled.

Some mining companies use two stage incinerators to dispose of general waste (wood, paper, etc.). Control of these incinerators is based on the exclusion of PVC waste and a two-stage incineration process with no smoke emission.

This type of incinerator/flare is controlled on an individual basis, and limits are set according to the best available technology for that type of plant.

The principal objective of the NWMS is to reduce the generation and environmental impact of all forms of waste, so that the socio-economic development of South Africa, the health of its people and the quality of its environmental resources are no longer adversely affected by uncontrolled and uncoordinated waste management.

The dates given in this section are those reflected in the NWMS Version ‘C’. In the other sections of this Action Plan, however, all dates have been adjusted to take into account the extended period for implementation of the short-term initiatives from 1999 to 2004.

The objective of treating hazardous waste prior to its final disposal is to minimise the environmental impact of the waste once it has been disposed of. The following priority initiatives for waste treatment were identified in the NWMS Version C:

• DEAT will review and revise existing air emission standards on thermal treatment facilities to ensure the protection of public health and the environment. The initial objective is that by 2002, all thermal treatment facilities will have been upgraded to comply with the revised standards, or alternatively will have been decommissioned.
• The planning for a system of well-functioning medical waste treatment plants will be completed by the year 2002 and additional treatment plants will be established thereafter. Medical waste collection and treatment systems in rural areas will be put in place during the period 2006 to 2010.
• DEAT will initiate national surveys to identify the amount and categories of hazardous waste requiring treatment throughout the country.
• DEAT will facilitate an investigation into the desirability and feasibility of a national hazardous waste treatment facility. The investigation will involve all relevant stakeholders.
• A public awareness and waste management education campaign will be introduced to focus on the hazards of medical waste and legal responsibilities of medical waste generators.

Waste disposal is the final waste management option in terms of the integrated waste management hierarchy. Although waste minimisation, recycling and treatment will reduce the amount of waste that requires disposal, a portion of the waste stream will always require final disposal at a disposal site. The priority initiatives identified for waste disposal are as follows:

• All medium and large landfill sites will be registered, permitted and operated in accordance with the DWAF Minimum Requirements (Second Edition, 1998) by 2005. All communal and small landfill sites will be registered and operated in accordance with the DWAF Minimum Requirements (Second Edition, 1998) and the promulgated regulations by 2005. A system of regional landfills will be promoted. The imposition of disposal tariffs that reflect the actual costs of disposal will be encouraged.
• Salvaging on landfills will be formalised and controlled by 2003 as an interim measure, but will be phased out completely in the longer term.
• DEAT, in collaboration with relevant government departments, will initiate a process to identify suitable areas for the establishment of hazardous waste treatment and disposal sites. Sites will be established with the full involvement of local and provincial government and the private sector, and private enterprise will be involved in the operation and management of these sites. Co-disposal of hazardous waste will be gradually phased out as new waste treatment and disposal technologies are developed and implemented.
• During the short-term period, disposal of mining and power station waste will comply with a permitting process that is integrated with the Environmental Management Programme Report (EMPR) process. A development programme for integrated management of mining and power station waste will start in 2002. At the same time, new closure requirements will be promulgated, and abandoned mine waste sites will be placed on an inventory and assessed, in accordance with the DWAF programme for remediation. This programme will establish an integrated waste management plan for remediation of abandoned mine sites, to be in operation by 2004.
• The DWAF Minimum Requirements will be reviewed every five years, or more often if considered necessary.

The priority initiatives for hazardous waste collection and transportation (general waste collection and transportation is addressed in the Action Plan for General Waste Collection) which are addressed in this Action Plan are:

• A safe collection and transportation system for hazardous waste will be developed. This system will include the registration and certification of transporters (by 2000), implementation of a waste manifest system (by 2001) and the development of a network of collection points (by the end of 2002).
• DEAT will develop guidelines for the safe management of medical waste by 2001, which will include guidelines for the separation of waste at source into infectious waste that requires incineration (according to the Human Tissues Act) and non-hazardous medical waste that can be disposed of by alternative methods.
• DEAT will prepare guidelines for provincial government for the collection and transportation of hazardous waste that will ensure integration of all regulations relating to the transportation of hazardous materials.

Prior to 1990 all types of waste were indiscriminately disposed of, often with limited or no pre-treatment of hazardous waste to minimise its environmental impact. The main reasons for these practices was the lack of coherent environmental legislation, regulations and guideline documents, coupled with insufficient enforcement of the existing legislation, and a poor environmental ethic in many sectors of the South African society.

Historical and current waste management practices have resulted in significant impacts on South Africa’s biophysical and social environment. The NWMS and its Action Plans were developed to address existing problems and improve the current situation and provide for integrated waste management plan for the future. A number of problems associated with waste treatment and disposal were identified, and this Action Plan seeks to address these problems.

The main problems associated with the treatment and disposal of waste that have been identified are:

• National government (DEAT and DWAF) has insufficient financial and personnel resources to effectively administer and enforce the existing environmental legislation. This situation has resulted in illegal dumping and an apparent reluctance on the part of some disposal site owners to comply with the current waste disposal standards.
• Knowledge and experience in the field of waste treatment and disposal lies predominantly within DWAF. As DWAF is understaffed and is obligated, in terms of the NWA, to implement water quality-related source control, it will not be able to second staff to DEAT for the implementation of the NWMS.
• Limited technical and environmental expertise at the local and provincial level of government will impact on the effective planning, development and establishment of waste disposal facilities.
• Due to a lack of resources provincial governments have not accepted the responsibility of managing the hazardous waste stream (treatment facilities/disposal sites).
• Many disposal or treatment facilities, including medical waste, are not properly managed, and will be unable to comply with the expected standards. They are also often poorly located and create unacceptable environmental conditions for adjacent communities.
• The legislative control and enforcement of existing standards within the waste treatment field is inadequate. DEAT have only 6 air pollution control officers operating throughout the country.
• The current classification system and emission standards applicable to incinerators need to be revised.
• The current definition of medical waste is inadequate and will be revised.
• There are many waste disposal sites, which are still impacting on the physical and social environments, due to poor planning in the past. A lack of enforcement and resources is delaying the remediation of these sites.
• Due to poor controls and standards, medical waste, hazardous waste and sewage sludge are being illegally dumped or disposed of at sub-standard waste disposal sites, often without appropriate pre-treatment. These practices result in increased health risks.
• Informal salvaging at the working face of landfills is widespread in South Africa. This practice is problematic, as salvagers are exposed to health and safety risks, and proper operation of the landfill is disrupted.
• There are no guidelines available for the separation of non-infectious waste and chemical hazardous waste from the medical waste stream, and personnel are inadequately trained in this regard.
• There is widespread public opposition towards the incineration of wastes, as well as the location of many waste disposal and treatment facilities.
• The cost of modern treatment technologies and environmentally acceptable disposal of waste is high in comparison to those costs incurred for the management of waste in the 1980’s. The waste generator is not used to high disposal costs, and often does not understand why high costs/tariffs are necessary. This negative perception can be addressed with well-designed environmental education and public awareness programmes.
• The Minimum Requirements for the Classification, Handling and Disposal of Hazardous Waste, 2^nd edition, published in October 1998, is inadequate in critical aspects. Features that need attention include: the development of the concept of a landfill risk factor (based on a decrease in risk due to the landfill design and operation), and a revision and augmentation of the list of compounds and wastes that have been rated as hazardous. It is most important that standards for the minimisation, recycling and treatment of hazardous waste be developed.
• The Minimum Requirements for Waste Disposal by Landfill, 2^nd edition, published in October 1998, are sometimes applied to temporary storage and handling facilities for waste, such as waste transfer stations and recycling plants. The Minimum Requirements for such waste facilities are inappropriate, and unrealistically conservative in some respects and appropriate and practicable Minimum Requirements must be developed for such facilities.
• The current treatment and disposal guidelines for coal combustion and mining wastes are considered to be inadequate.
• There are inadequate controls regarding the transportation of hazardous wastes.
• The storage of chemicals and hazardous waste residues (paint, dyes, solvents etc) on industrial and farming sites without proper controls is commonplace. This situation exists because of the reluctance of these waste generators, particularly in the smaller industries, to pay higher disposal tariffs, inadequate planning (exacerbated by poor waste collection services and ineffective controls within the larger metropolitan areas.

There are a number of key stakeholders that have been involved in the development of the Waste Treatment and Disposal Action Plan, and whose continued involvement will be crucial to the successful implementation of the Action Plan:

Industry, as the major generator of hazardous waste, will be consulted during the development and implementation of Action Plans for the treatment and disposal of general and hazardous waste. Industry has been involved and has supported the NWMS to date, but their support is even more important in the future to improve the situation regarding waste treatment and disposal.

The major industrial sectors identified include:

• Mining and Metallurgy
• Agriculture
• Medical Services including Provincial Hospitals
• Power Generation (Eskom)
• Chemical and Allied Industries
• Waste Management Industry, including the Institute of Waste Management
• Petrochemical Industries

The contribution of industry will also be essential for:

• The development of appropriate waste treatment facilities (in partnership, if necessary).
• The establishment of minimum requirements for mining and coal combustion wastes, auditing procedures and feasible closure plans.

These organisations have contributed to date, but the co-operation and involvement of all sectors of civil society is essential in decision-making processes regarding the siting of treatment and disposal facilities. These groups should also be involved in auditing, and assist with capacity building and public awareness campaigns.

The national government departments that have an interest in waste treatment and disposal include DEAT, DWAF, Department of Minerals and Energy (DME), Department of Health (DoH), and to a lesser extent the Departments of Labour, Trade and Industry, Constitutional Affairs, and Transport. A single department, DEAT, will be responsible in collaboration with all stakeholders for ensuring the setting of appropriate standards and guidelines for treatment and disposal.

The provincial authorities are major generators of medical waste, and are responsible for planning for the treatment and disposal for hazardous waste in their Province. The control, auditing and enforcement of some treatment and disposal facilities may also be delegated to these authorities. The main provincial authorities involved are the provincial environmental and health departments.

Local government will be involved in the registration of waste disposal sites, the development and operation of general waste landfills (including the setting of disposal tariffs), as well as the identification of sites, which are impacting on public health and the environment and require closure and rehabilitation.

The professional organisations, such as the Institute of Waste Management of Southern Africa (IWM (SA)), the Industrial Environmental Forum (IEF), the South African Medical and Dental Council, the Nursing Council, etc. can play an important role in the dissemination of information and capacity building in waste management.

The participation and co-operation of people undertaking informal salvaging at landfills will be required in order to formalise and control this practice and phase it out completely in the longer term.

Members of the public in their individual capacities will be free to give input into all aspects concerning waste treatment and disposal.

The successful implementation of the waste treatment and disposal Action Plan depends to a certain extent on factors outside the control of the implementing authority. These factors can be considered risks, which could impede the success of the NWMS project. Risk factors relevant to the implementation of this Action Plan include the following:

• Responsibilities and duties assigned to certain authorities in terms of this Action Plan may not be accepted e.g. provincial environmental departments may not accept the responsibility to register landfill sites. Negative responses will delay the implementation of the Action Plan.
• Due to constrained budgets and changing priorities, DEAT, DWAF, the provincial environmental departments and the local authorities may not be able to allocate the necessary resources (finances and qualified personnel) required to implement the responsibilities allocated to them in this Action Plan. The lack of resources will prevent the effective registration and permitting of landfill sites, delay the closure of sites which have a negative impact on the environment and may delay or prevent the development of waste treatment technologies, particularly in the hazardous waste field (organics, medical waste etc).
• Insufficient attention has been given to developing the necessary institutional and organisational structures in the relevant national departments and the provincial authorities which will ensure that the available qualified staff are used effectively. Failure to address this issue will delay the implementation of this Action Plan indefinitely.
• The lack of capacity within DEAT, as lead agent for implementation of the NWMS, is a matter of concern.
• Because of insufficient personnel within DWAF and the provincial environmental departments, inadequate enforcement of regulations may lead to an increase in illegal dumping, particularly when more advanced and expensive waste treatment technologies are introduced.
• At present the capacity building programmes and public awareness programmes are unsuitable or inadequate. Well-accredited programmes are required which will cover waste treatment technology, and the financial implications and associated environmental benefits of an effective integrated waste management system. The continued lack of suitable training programmes may result in the continued resistance to incineration as an appropriate technology for the treatment and destruction of wastes in specific waste categories, e.g. medical waste, as well as resistance to the increased costs of effective waste treatment and disposal and a consequent increase in illegal dumping.
• The development of hazardous waste treatment facilities and the high capital costs, which will be incurred, will require special funding mechanisms to be in place. The financial impact of this new technology and the associated treatment cost could result in an increase in illegal disposal to the natural environment or to sewers and the possible closure of certain small, medium and micro businesses, that cannot afford to treat or dispose of their waste properly.

A Task Team was established to develop the short-term priority Action Plan for waste treatment and disposal. The Task Team consisted of representatives from DEAT and DWAF, and South African and Danish Consultants.

Following an analysis of the problems, the stakeholders and the risks, a Logical Framework Analysis (LFA) matrix was prepared. The LFA matrix contains an outline of the logical steps, which are necessary to achieve the Action Plan objectives, provided that the assumptions are realised. The LFA matrix therefore constitutes a summary of the objectives, outputs/deliverables and activities necessary to give effect to the outputs inputs, assumptions or external factors and monitoring and verification. The LFA matrix for this Action Plan is attached as Annexure A. The elements of the matrix are described in greater detail below.

The development objective of the NWMS is the reduced generation and environmental impact of all forms of waste, so that the socio-economic development of South Africa, the health of its people and the quality of its environmental resources are no longer adversely affected by uncontrolled and uncoordinated waste management.

The long-term objective for waste treatment is to ensure that all current and new legislation, regulations, guidelines and standards for the total waste stream, from generator to final disposal, and all waste treatment facilities, are enforced by 2012.

For waste disposal, the long-term objective is to ensure that all unavoidable wastes are safely collected, transported and disposed of at waste disposal facilities developed and operated in accordance with the DWAF Minimum Requirements and/or other appropriate standards by 2012.

The immediate objectives, to be achieved within the period of July 1999 to December 2004 are described in Section 1.3 and summarised as follows:

1. All waste treatment facilities will be controlled by means of a regulatory framework, based on a waste classification system, by December 2004.
2. A system, including guidelines and regulations, will be developed and implemented to ensure the safe handling, collection and transportation of hazardous waste by the December 2004.
3. Air emission standards for all waste incineration facilities will be reviewed, revised and enforced by December 2004.
4. By December 2002, plans for a system of medical waste treatment plants will be developed, guidelines for the safe management of medical waste will have been developed and implemented and a public awareness and education campaign will have been conducted.
5. The desirability and feasibility of regional/quasi-provincial waste treatment facilities will be investigated by 2004. As part of this investigation, a national survey of the amount and categories of hazardous waste requiring treatment will be undertaken.

1. All waste disposal facilities will be registered by December 2001, and the register will be updated biennially thereafter.
2. Facility owners Plans will develop plans for implementing the DWAF Minimum Requirements at all Section 20 waste disposal facilities by December 2002. All registered medium and large landfills will be permitted by December 2004. Regulations for controlling communal and small landfills will be promulgated, and all communal and small landfills will be controlled in terms of these regulations and the Minimum Requirements by December 2004.
3. Permit conditions, applicable regulations and the DWAF Minimum Requirements will be enforced at all Section 20 waste disposal facilities from 1999 onwards.
4. As an interim measure, existing salvaging on landfills will be formalised and controlled by 2003, but phased out completely in the longer term.
5. A regulatory framework, integrated with the EMPR process and based on a waste classification system will be developed for all mining and coal combustion waste disposal facilities by December 2002.
6. All provinces and/or regions will be adequately serviced by hazardous waste collection and disposal facilities by December 2004.
7. The DWAF Minimum Requirements will be reviewed, augmented and amended where appropriate, and an updated 3^rd Edition will be published by December 2003.

The outputs/deliverables that will facilitate successful implementation of the Waste Treatment and Disposal Action Plan, providing that all the critical assumptions are realised, are:

• Medical waste facilities, including incineration and alternative treatment technologies.
• Hazardous waste facilities, including thermal destruction and alternative treatment technologies.
• Crematoria facilities (human and animal).
• Recovery works, for liquid, solid or energy recovery.
• Animal waste - blood, skins, hides, by-products, fat, bone meal and fishmeal.
• Oil recovery.
• Electroplaters and Metal Finishers.
• Gold and acid recovery from mine dumps.

In order to ensure effective implementation of the Waste Treatment and Disposal Action Plan, a number of activities have been identified for each output, which must take place in order to produce the outputs/deliverables of this Action Plan. These activities are described below.

A major objective of the National Waste Management Strategy is to promote alternative approaches to the management of waste that will lead to waste avoidance, recycling, re-use and utilisation. For unavoidable hazardous waste, treatment to mitigate its environmental impact prior to disposal is a key objective. There are currently standards for the treatment, handling and disposal of hazardous waste i.e. the Minimum Requirements, that if enforced would lead to an immediate improvement in the environmental impact of wastes. The evaluation and upgrading of these standards can then be accomplished and systematically enforced in the short term, i.e. before December 2004.

The review of legislation will be undertaken as part of the ongoing Pollution and Waste Law Reform Process. However, should the Law Reform Process not be able to undertake the required legal reviews within the specified timeframes, specialised working groups will be constituted to undertake the review themselves, or have the reviews undertaken on their behalf.

The following key activities that will lead to an improvement in waste treatment practices have been identified:

DEAT will constitute a Classification System Working Group (CSWG) and draw up the Terms of Reference for this team, in collaboration with all relevant stakeholders. Classification systems for treatment facilities that are available both locally and internationally will be identified and reviewed in consultation with the stakeholders. A draft classification system that is considered appropriate for South Africa will be drawn up, scoped with MINTECH Workgroup 3, the CEC and other stakeholders, and published for comment. The comments received from all stakeholders will be considered in drafting the final document. The comments received from stakeholders will be published and the CSWG’s comments will be made available as an addendum to the final report. The classification system will be finalised and approved at the appropriate level before publication, which will take place by December 2000.

DEAT will set up a register of waste treatment facilities by December 2002. The register will be based on the classification system developed above and data will be accessed from the WIS. The lists will be broken down into the facilities located in each province and will be updated on a bi-annual basis. The provincial environmental departments will be sent an updated list of treatment facilities bi-annually and will be required to report any developments and changes to DEAT and the WIS six months after receipt of the list.

DEAT will constitute a Treatment Facilities Regulations Working Group (TFRWG) for each class of facility identified by the CSWG (see Output 1 above). Prioritisation of the facilities in terms of their potential risk to human health and the environment can be done in collaboration with all stakeholders. Regulations and standards for all classes of facilities will be completed by the year 2004. Each TFRWG will review existing guidelines, standards and regulations available both locally and internationally in consultation with all stakeholders. Draft documents containing appropriate regulations and standards for each class of facility will be published and made available to all I&APs, and discussed with MINTECH Workgroup 3 and the CEC. Multisectoral workshops will be held to obtain input from I&APs and a report on the comments received will be prepared and circulated. Following approval by the Minister, the finalised regulations and standards will be published and distributed to all provincial environmental departments. DEAT and the provincial environmental departments will ensure that all facility owners and operators become aware of the new guidelines and regulations and are given a timetable for their implementation. All facilities, particularly those identified as high priority, will be required to implement the standards and upgrade or close unsatisfactory facilities within 2 years of the publication of the finalised regulations and standards.

DEAT will set up a Hazardous Waste Collection and Transportation Working Group (HWCTWG) and draw up the Terms of Reference for this team in collaboration with the Networking Group and all other stakeholders. The HWCTWG will review existing regulations for the collection and transportation of hazardous materials and develop new integrated guidelines by December 2001. The current South African regulations, both national and provincial and international regulations such as the Basel Convention on the cross-boundary movement of hazardous waste will be reviewed. Integration of the regulations with those for the transport of hazardous materials, such as those contained in the National Road Traffic Act (Act 93 of 1996) and the SABS Codes 0228 to 0232 is essential. The regulations will include a registration and certification system for hazardous waste transporters that is compatible with the Waste Information System. A "Duty of Care" undertaking will be included for waste generators that ensures that they retain the ultimate responsibility for ensuring that their waste is only transported by a registered company and is disposed of in an appropriately permitted waste disposal facility. A waste manifest system that tracks the waste from "cradle to grave" will be developed by December 2003. Limited waste manifest systems that have been developed by waste transporters themselves are already in use.

The HWCTWG will also draw up guidelines and standards in collaboration with all stakeholders for hazardous waste collection points, particularly for SMMEs. These collection points would also act as transfer stations where hazardous wastes are sorted and bulked for transportation to the appropriate recycling, treatment or disposal facility. Once the guidelines have been accepted and published, the provincial environmental departments possibly in collaboration with neighbouring provinces will draw up plans for a network of hazardous waste collection stations/transfer stations for their province. Once the plans have been approved by DEAT the network will be implemented. Partnerships between the public and private sector will be important in setting up and operating these stations.

DEAT will constitute an Air Emission Standards Working Group (AESWG) and draw up the Terms of Reference for this team in collaboration with the Networking Group and all other stakeholders. The AESWG will review existing local and international air emission standards and draw up draft standards in consultation with all I&APs by December 2000. The document will include guidelines on the actions to be taken with facilities that do not conform to the regulations. Issues to be considered include: the nature of the waste incinerated, e.g. medical or chemical waste; the quantity of waste incinerated; the age of the facility; its location; and the availability of alternative treatment facilities. Consideration must also be given to the measuring/analytical methods and modelling techniques to be used for different components of the emissions, and the practicability/suitability of these methods and techniques. The draft standards will be made available to MINTECH Workgroup 3, the CEC and all other I&APs. A multisectoral workshop will be held in order to ensure input from all stakeholders. A report on the workshop and all other inputs and comments from stakeholders will be made available. The final guidelines and regulations document will be published as soon as possible after approval by the Minister of Environmental Affairs and Tourism, and no later than December 2001. The AESWG will review the guidelines and standards at least once a year to ensure that they are in line with national needs and with developments in legislation both nationally and internationally. Approved amendments or new guidelines will be published, as required.

From January 2001 onwards. DEAT, in collaboration with the provincial departments, or the PEDs will assign a responsible staff member for Air Quality who will draw up a programme of site visits to audit all waste incineration facilities. Due to resource constraints, site visits will be prioritised according to the potential risk to human health and the environment, and will be done in collaboration with all stakeholders. The auditor will determine the required enforcement action in terms of the guidelines, and a timetable will be produced for enforcement of that action in collaboration with the appropriate authorities, the facility owner, the facility operator and other affected parties. The final action for facilities that cannot conform will be closure, subject to the availability of alternative facilities permitted in terms of the new guidelines (Output 9).

DEAT, in collaboration with the DoH, will set up a Medical Waste Management Guidelines Working Group (MWMGWG) and draw up the Terms of Reference for this team in collaboration with the Networking Group and all other stakeholders. The MWMGWG will review existing local and international guidelines for the management of medical waste. For example: the SABS Code of Practice 0248 based on the Canadian guidelines and regulating the management of infectious materials can serve as a starting point for the development of an improved system. The separation of infectious waste from the non-infectious waste stream will be emphasised, since a portion of the waste stream currently incinerated is classified as non-hazardous. This practice contributes to increased incinerator emissions and to higher costs for medical institutions. The standardisation of medical waste containers and labelling will be addressed. The working group will also consider alternative technologies for medical waste treatment, such as microwaving, autoclaving and other appropriate technologies, and provide guidelines on their acceptability and feasibility for replacing or supplementing incineration technology that is still common in South Africa. In order to reduce air emission problems consideration will also be given to restricting the use of halogenated plastics, particularly polyvinyl chloride, in medical equipment and waste containers that are to be incinerated.

DEAT, in collaboration with DoH, will develop and implement a medical waste awareness and education campaign in consultation with DWAF, provincial and local government, the South African Medical and Dental Council, the Nursing Council and other stakeholders. The objective is to raise awareness among the general public, particularly schoolchildren and health professionals, about the hazards associated with improper treatment and disposal of infectious waste. These programmes will focus on the need to reduce the amount of infectious materials that are discarded or disposed of without proper treatment. A survey will be conducted at the end of the campaign in order to assess its success and the need for continued reinforcement of the message.

DEAT, in collaboration with the provinces, will draw up guidelines for planning of treatment plants that will be able to treat medical waste efficiently and cost-effectively. The different needs of urban and rural medical facilities will be considered. In urban areas regional medical waste facilities that can service a large number of medical waste generators have already been implemented in some South African urban centres, and these have proven highly cost effective.

Each provincial government will assess its needs for medical waste treatment in both urban and rural areas, and draw up plans for the development of appropriate facilities in identified areas. Partnerships between the public and private sector will be important in setting up and operating regional facilities.

DEAT will facilitate a national survey to assess the amounts and types of hazardous waste generated in South Africa that require treatment. A lack of information in the past has hampered effective planning of waste treatment and disposal facilities. The need for Regional Waste Treatment Facilities (RWTF) that can destruct organic hazardous waste, and treat and recover valuable metals from inorganic wastes, will be assessed. Incineration is often the technology of choice internationally for the destruction of hazardous organic waste, but all the alternatives will be considered and recommendations made on the most appropriate technology for South Africa. Most stakeholders consider that the treatment facilities currently available in South Africa are inadequate, and consequently current disposal practices have an impact on the environment and place a burden on the hazardous waste landfills. Waste materials are also being stored, often in inadequate facilities, because methods of treatment, such as those available in most developed countries, are not generally available in South Africa.

The provinces will assess their needs and, with the assistance of DEAT, draw up joint plans for the implementation of such facilities. If it is determined that RWTF are required in the medium-term, one or two facilities will be established in those areas where the bulk of the waste is generated so as to reduce the high treatment cost and make the facility operate as cost-effectively as possible. Partnerships between the public and private sector will be important in setting up and operating the RWTF. Users of the RWTF would be required to pay for use of the facility.

A register of waste disposal sites will be developed and maintained by DWAF or possibly DEAT, based on the classification system contained in the DWAF "Minimum Requirements for Waste Disposal by Landfill", and other relevant disposal site classification systems. Data for the register will be accessed from the Waste Information System database. The local authorities will be requested to provide any outstanding or new site data according to the regulations.

The register will contain details of the locality and site of all waste disposal facilities in South Africa. New data gathered will be used to update the Waste Information System on a regular basis and will also give DWAF better insight into the environmental impact of sites not previously assessed.

DWAF, or the PEDs, using information obtained from the registration process and the WIS database, will identify those Section 20 waste disposal facilities not complying with the Minimum Requirements. The respective facility owners will be informed who will be required to submit the necessary reports and plans within realistic time frames, but before December 2002.

All plans and reports received will be reviewed by DWAF and the site owners informed of the approval of their reports and plans or the amendments required. In approving the documentation, DWAF will set time frames for implementation and upgrading of the sites.

The DWAF, or the PEDs, will have the responsibility of compiling a list of those medium and large-sized landfill sites, which do not have permits, and then of refining this list according to a priority rating (assessment based on the environmental impact of the individual sites). The respective landfill owner will subsequently be consulted and instructed to apply for a permit within a specific time frame, in accordance with the EIA Regulations, and using the Minimum Requirements as a guideline document. All permits timeously applied for should be issued by 2004.

DWAF, in collaboration with DEAT, will prepare draft regulations, in terms of the ECA, for controlling Communal and Small-sized landfills. The draft regulations will be published for stakeholder comment. Following consideration of the comments received, the regulations will be finalised and gazetted by December 2000.

From 1999 onwards DWAF, or the PEDs, will assign personnel to draft site inspection registers and protocols, based on the location and environmental sensitivity of individual Section 20 waste disposal facilities. Personnel will conduct site audits and prepare site audit reports as frequently as required by the inspection registers. The audits will be used as a basis for identifying facilities that do not comply with the applicable permit conditions, regulations and Minimum Requirements. Facility owners not complying will be required to address non-compliance within a specified timeframe.

DWAF, or the PEDs, will enforce the Minimum Requirements at all landfill sites to ensure that informal salvaging is formalised and controlled. The landfill owner must enter into negotiations with the salvagers, or their accepted representative, and reach agreement on the control of the salvaging operation on the site, primarily to reduce the safety and health risks to the salvagers. The agreement reached will be documented, and the site-operating plan amended to accommodate the agreed salvaging operation. For a site where a permit has already been issued, the agreement and/or revised operating plan may be included as a permit stipulation, by means of a permit amendment. DWAF will be responsible for enforcing the conditions of the new or amended permits. Salvaging will not be allowed to commence on landfills where it is not currently taking place.

National government (DME, DEAT and DWAF) will constitute a Classification System Working Group (CSWG). The terms of reference for the working group will be drafted in consultation with the relevant stakeholders and all tiers of government.

The working group will review all existing classification systems in South Africa e.g. the Minimum Requirements classification system and the relevant SABS Codes of Practice, and ensure integration of these systems with the EMPR process. A classification system will be drafted and discussed with all relevant stakeholders, including the MINTECH Workgroup 3 and the CEC, within a scoping process (for example, by means of workshops). This draft classification system will then be published for comment.

The classification system will be finalised taking into account all stakeholders comments and be approved by the Ministers of the relevant national government departments before promulgation by December 2000.

National government (DME, DEAT and DWAF) will constitute a Permitting System Working Group (PSWG). The terms of reference will be developed for the Working Group with the input of all stakeholders and all spheres of government.

The PSWG will review all existing permitting systems, Minimum Requirements, Aide-Memoirs, guidelines and codes of practice, excluding all National Water Act and Water Services Act mandates. Thereafter, a new or revised draft permitting system and guidelines, integrated with the EMPR process and based on the classification system developed previously (see Disposal Output 7), will be drawn up and discussed in a consultation process before being finalised. The final documents will consider all stakeholder comments. The final permitting system and guidelines will be approved by the relevant Ministers prior to promulgation by December 2002.

Provincial environmental departments, with the assistance of the relevant national departments, will identify the need to develop hazardous waste disposal facilities through the preparation of the integrated hazardous waste management plans.

Inter-provincial committees (new or existing) will consider the viability of partnerships where possible. Provincial environmental departments, in collaboration with local government, will establish a Hazardous Waste Task Team (HWTT), which should include personnel involved with the integrated waste (general and hazardous) planning function.

The HWTT will initiate a process to identify suitable areas for the possible development of hazardous waste disposal facilities in terms of the Minimum Requirements and EIA to ensure stakeholder involvement throughout the process.

DWAF, together with DEAT and the PEDs, will constitute Minimum Requirements Revision Working Groups (MRRWG) that will update, augment and amend the three Minimum Requirements documents to address gaps, such as issues relating to waste transfer and recycling facilities. Terms of Reference and a Project Plan for each working group will be drafted and accepted after consultation with relevant stakeholders and tiers of government.

DWAF has already initiated, and will continue to facilitate, a process to invite comment on the documents based on implementation experience. All comments received will be considered in the drafting of the 3^rd editions of the Minimum Requirements documents. Draft 3^rd editions will be released for final comment. Final documents will be endorsed by the MRRWG before publication by December 2003.

The following inputs are required to undertake the activities described in section 3.5 over a period of 5.5 years:

The funds for the for the development of the classification system and standards and guidelines for all waste treatment facilities, plus the funds for the monitoring and auditing of incineration facilities will be obtained from the general fiscus. Funding will also be sourced from the fiscus for: for the development of a classification and permitting system for mining and coal combustion wastes; developing procedures for the effective implementation of minimum requirements and enforcement of permit conditions (such as monitoring, auditing and reviewing plans for upgrading); a technical working group to review the minimum requirements documents and hazardous waste disposal facilities. Upgrading of disposal sites and the development of new hazardous waste disposal facilities will be funded by disposal tariffs.

The estimated cost and total human resource requirements for the above mentioned short-term priority initiatives in the three tiers of government and where applicable the industrial sector are given in Sections 3.6.1 – 3.6.3 and summarised in Table 1.

DEAT will act as lead agent in the development of a system for the safe collection and transportation of hazardous waste and guidelines for the safe management of medical waste. It is estimated that two staff members dedicating 50% of their time over 5.5 years will be required to carry out these activities. The cost of these activities is estimated to total 0.825 million Rand (50% of 2 persons’ time over 5.5 years = 5.5 person years at an annual salary package of R150 000). In addition, DEAT will act as lead agent in the development and implementation of a public awareness and education campaign regarding the hazards of medical waste and the legal responsibilities of medical waste generators. The estimated cost of developing and implementing this campaign over a three year period is 5 million Rand.

DEAT will act as lead agent for the development of (i) a classification system for waste treatment facilities, (ii) a register of waste treatment facilities, (iii) regulations and standards for waste treatment facilities and (iv) revised air emission standards for waste incineration facilities. It is estimated that 4 full time staff members will be required until December 2002 to carry out all the activities necessary to achieve these outputs. The total cost of these outputs is estimated to be 2.1 million Rand (4 persons over 3.5 years = 14 person years x R150 000).

DEAT is currently responsible for the monitoring and auditing of waste incineration facilities. In order effectively monitor and audit waste incineration facilities according to the revised Air Emission Standards, it is estimated that 18 staff members, each dedicating 50% of his/her time, will be required nationally (on average 2 per province). The total cost of this initiative is therefore estimated to be 5.4 million Rand (50% of 18 persons’ time over 4 years = 36 person years x R150 000). It is anticipated that this monitoring and auditing function will be transferred to the provincial environmental departments over time. When this transfer occurs, the above cost will be transferred from national to provincial level; this aspect is addressed in greater detail in the Implementing Instruments Project Plan.

In collaboration with the provincial environmental departments, DEAT will prepare a plan for establishing a system of medical waste treatment facilities. The estimated cost for developing this plan is 0.9 million Rand, over 3 years.

As lead agent, DEAT will facilitate an investigation into the desirability and feasibility of regional waste treatment facilities, including a national survey of the amount and types of hazardous waste generated. The estimated cost for this investigation is 1.25 million Rand, over 5 years.

DWAF Head Office staff are currently responsible for establishing and maintaining a register of waste disposal facilities, permit administration and for revising the Minimum Requirements, as well as other waste management-related matters. In addition, the responsibility for permitting, monitoring and auditing of hazardous waste disposal facilities rests with DWAF Head Office. In order to perform these functions effectively, 6 full time staff members are required. The estimated total cost of performing these functions is 4.95 million Rand (6 persons x 5.5 years = 33 person years x R150 000). It is expected that all these waste management responsibilities will be transferred to DEAT over time. When this transfer occurs, the above costs will be transferred from DWAF to DEAT; this aspect is addressed in greater detail in the Implementing Instruments Project Plan.

Responsibility for: (i) enforcing the development of plans for implementing Minimum Requirements, (ii) permitting of landfills (including formalisation and control of salvaging), and (iii) monitoring and auditing of Section 20 disposal facilities currently rests with the DWAF Regional Offices. In order to perform these functions effectively, an average of 3 full time staff members per DWAF Regional Office is required, and the estimated total cost of performing these functions is 22.28 million Rand (3 persons x
5.5 years x 9 regions x R150 000). These functions may be transferred to the provincial environmental departments over time, as they acquire the necessary capacity. When this transfer occurs, the above cost will be transferred from DWAF to the PEDs; this aspect is addressed in greater detail in the Implementing Instruments Project Plan.

National Government (DME, DEAT, DWAF) will be responsible for developing a classification and permitting system (including minimum requirements and guidelines) for mining and coal combustion wastes. In order to meet the target dates of December 2000 (classification system) and December 2002 (permitting system), 2 full time staff members will be required. The cost of departmental staff for developing the classification and permitting system is estimated to be 1.05 million Rand (2 persons over 3.5 years = 7 person years x R150 000). It is estimated that a further 2.5 million Rand will be required over 3.5 years, to cover the cost of establishing task teams, technical working groups, etc.

DEAT and DWAF are responsible for capacity building in all sectors. The estimated cost of fulfilling this responsibility is estimated to at R 1.68 million (20% of 1 person’s time per DWAF Regional Office over 4 years and 50 % each of 1 DEAT and 1 DWAF Head Office staff member’s time over 4 years = 11.2 person years x R150 000).

Where necessary, appropriately qualified consultants will be contracted to assist in the development and drafting processes described above. These costs have not been included in most of the estimates, but are expected to be derived from the department budget.

The PEDs will be responsible for implementing and monitoring certain components of the system for safe collection and transportation of hazardous waste within their province viz. the registration and certification of transporters, the waste manifest system and possibly the establishment and control of hazardous waste collection facilities. It is estimated that one staff member dedicating 30% of his/her time will be required in each province to perform these functions. The total cost of implementing this initiative is estimated at 1.215 million Rand (30% of 1 person’s time over 3 years x R150 000 x 9 provinces).

Staff of the PEDs will assist in the development of a plan for establishing a system of medical waste treatment facilities, and in investigating the feasibility of regional waste treatment facilities. It is estimated that one staff member dedicating 20% of his/her time per province will be sufficient, and that the total cost involved will be 1.35 million Rand (20% of 1 person’s time over 5 years x R150 000 x 9 provinces).

Capacity building programmes developed by DEAT will be utilised to develop capacity in civil society and the local authorities. The cost of this responsibility is estimated at 1.08 million Rand over 4 years (20 % of 1 person’s time per provincial environmental department over 4 years x R150 000).

All Section 20 disposal facility owners will be required to upgrade their sites to comply with the permit conditions and/or the Minimum Requirements. The estimated total cost over a 5 year period is 750 million Rand (150 million Rand per year).

Approximately one person, dedicating 20% of his/her time per local authority
(800 persons) will be required to manage the above process. Therefore the total personnel cost is estimated to be 132 million Rand (20% of 1 person’s time per local authority x 800 x 5.5 years x R150 000) over the short term.

It is estimated that formalisation and control of salvaging will cost 0.025 million Rand per landfill. Although salvaging does not take place on all landfills, it is estimated that salvaging occurs on about 450 landfills. The total cost of formalising and controlling salvaging is therefore estimated at 11.25 million Rand, over 3 years.

The development of additional hazardous waste disposal facilities is estimated to cost 50 million Rand per site. It is assumed that the initial capital cost of developing a facility, together with the operating cost, will ultimately be recovered from users of the facility through disposal tariffs.

The following assumptions have been made in developing this Action Plan. Unless these assumptions are met, it will not be possible to fully realise the objectives of this Action Plan:

• Waste treatment and disposal is regarded as a priority issue in all tiers of government and by decision makers.
• IP & WM Policy and the NWMS are approved by Cabinet and accepted by all stakeholders by December 1999.
• The enabling legislation is adequate.
• Clear responsibilities are assigned and accepted by all relevant parties by December 1999.
• DEAT, DWAF, provincial and local governments have sufficient suitably qualified staff.
• The necessary finances are available.
• Adequate capacity building in the public sector to ensure positive interaction with stakeholders.
• MINTECH Workgroup 3 and the CEC function effectively.
• The WIS will be operational by July 2001. If implementation of the WIS is delayed, the best available information will be used to complete this Action Plan.
• All stakeholders participate in the different activities of this Action Plan.
• The systems, standards, requirements, etc. that are developed are accepted by all sectors of society.
• Waste generators are willing and able to pay for the increased costs for improved treatment standards.
• Disposal facility owners co-operate in registering their facilities, even though this may result in additional expenditure to upgrade their site(s) to meet the Minimum Requirements.

Progress will be monitored through the delivery of the outputs according to schedule. It is important that the progress of the Action Plan is monitored effectively, in order to timeously address problems that may arise during implementation.

Monitoring mechanisms will include the following:

• All waste disposal sites will be registered by 2001 and regulated and permitted by 2004.
• All treatment facilities will be registered, classified where necessary and controlled through effective regulations and enforcement by appropriate national or provincial environmental departments by 2004.
• All mining and coal combustion waste disposal facilities classified and controlled by means of an effective regulatory system by 2002.
• Adequate hazardous waste disposal facilities established and operational in South Africa by 2004.
• New air emission standards enforced by 2004.

• The approval of a treatment classification system, the compilation of a register of treatment facilities and waste treatment guidelines and regulations published in the Government Gazette.
• New air emission standards for incinerators developed and gazetted.
• Effective monitoring and auditing programmes introduced for incineration facilities by provincial authorities.
• A registration system for waste disposal facilities developed.
• Regulations for controlling communal and small-sized landfills promulgated.
• Effective monitoring and auditing programmes for Section 20 waste disposal facilities introduced – auditing reports subsequently made available.
• Section 20 disposal facility owners submit plans to upgrade sites.
• Classification and permitting system (including guidelines) for mining and coal combustion wastes, integrated with the EMPR process, developed and published / gazetted.
• Hazardous waste plans prepared by provincial authorities and initiation of the process to identify and develop new hazardous disposal facilities.
• The publishing and implementing of the 3^rd edition of the Minimum Requirements.

• Working groups for the development of a classification system and guidelines for waste treatment facilities established and functional.
• The Waste Information System operational and the process to register waste treatment facilities and waste disposal facilities functioning.
• Working group to revise air emission standards for waste incineration facilities established and functional.
• Adequate personnel appointed by DEAT or PEDs to audit waste incineration facilities.
• Working groups to develop a classification and permitting system for mining and coal combustion wastes established and functional.
• Regular updating and amendment of the DWAF Minimum Requirements documentation in operation.
• Adequate personnel appointed by DWAF or PEDs, to effectively audit Section 20 waste disposal facilities.
• Plans submitted by Section 20 disposal facility owners to upgrade sites.
• PEDs establish project team/s to investigate the development of required hazardous waste disposal and/or treatment facilities.

The period from January to September 1999 is a transitional phase during which the NWMS project responsibilities move from the Danish and South African consulting teams to DEAT and DWAF. DEAT will be the environmental lead agent for waste and will assume responsibility for the integrated waste management process.

The transfer of responsibilities requires that specific departmental personnel, referred to as departmental task leaders (DTL), are tasked with overseeing the implementation of the various Action Plans. The DTLs and project management group representatives constitute the Action Plan Implementation Group (APIG) that will assist with the implementation of the NWMS and the Action Plans. The APIG will review, guide and advise on the management of the implementation activities, the process, outputs, time frames, budgets and monitoring of the process. The APIG will also assist with the lateral and vertical integration and co-ordination of the Action Plans, not only between participating DEAT and DWAF staff but also in all levels of government. When the functions of those personnel identified as departmental task leaders change, due to reallocation of responsibilities, other appropriate staff will take their place. After September, the APIG will be replaced by DEAT, MINTECH Workgroup 3 and the CEC.

DEAT has initiated a process for the implementation of the National Waste Management Strategy and the Action Plans, that will include the development of a strategy for the institutional transition during June/July 1999.

Organisational and financial sustainability is dependent on the commitment of national government to allocate the necessary financial resources, as well as develop capacity and promote waste management awareness through projects driven by DEAT. Organisational and financial sustainability in provincial and local government depends on the availability of financial and personnel resources.

The time schedules established in this Action Plan are very constrained. If there is any delay, specifically in providing finance and personnel, as well as in enacting the required legislation, the implementation of this Action Plan will be delayed. Contingency plans need to be in place if delays are significant and impact negatively on the progress of the implementation of the NWMS initiatives.

To ensure the successful and sustainable implementation of the Action Plan for Waste Treatment and Disposal, commitment and dedication is required from the government personnel involved in the process, and support from their senior staff is necessary, both politically and in the allocation of staff members.

The Project Management Group (PMG), comprising DEAT/DWAF and DANCED, are currently managing the development of the Strategy and Action Plans, but the Action Plan Implementation Group (APIG) has the overall responsibility for finalising implementation of the Action Plans. After September, the APIG will be replaced by DEAT, the MINTECH Workgroup 3 and the CEC.

The development of the implementing instruments by DEAT and DWAF will take place during the period January to September 1999, and continue thereafter as and when required. These instruments consist of an Institutional Framework, Legislation, Funding Mechanisms, Partnerships and Public Participation, and Education and Awareness Campaigns.

The activities required to implement this Action Plan will be carried out by personnel in a number of different directorates in DEAT and DWAF, the provincial environmental departments, local government and Section 20 disposal site owners. Due to the wide scope of this Action Plan, certain personnel will be key to some activities, but will have no involvement in others. It is therefore of the utmost importance that the relevant directorates within national and provincial departments are identified, and notified as soon as possible. In cases where regional directorates or provincial offices will be carrying out activities, such as monitoring and auditing, it may be necessary to provide for central co-ordination of these activities.

The current and future responsibilities envisaged for implementing this Action Plan are detailed below.

The Organisational Chart for the implementation of the Waste Treatment and Disposal Action Plan is presented in Annexure C.

After completion of the implementation of this Action Plan for Waste Treatment and Disposal in the year 2004, the plan will be evaluated by DEAT, in consultation with DWAF, the CEC, the provincial environmental departments, local government and other stakeholders. An evaluation report on the achievement of the immediate objectives and delivery of all outputs within the specified timeframes will be prepared by DEAT. The evaluation report will include conclusions and recommendations for the next four-year Action Plan (medium-term), which will be discussed with the CEC, MINTECH Workgroup 3 and other stakeholders.

Based on the results achieved after the implementation of the short-term Action Plans, the medium-term and long-term plans of the NWMS which involve implementing the medium and long term initiatives, will be reviewed and revised if necessary. Based on this review, DEAT will prepare a new generation of Action Plans which will achieve the medium and long-term objectives of the National Waste Management Strategy, including the objectives set for waste treatment and disposal.

The NWMS and Action Plans cover a period of fourteen years until full implementation in the year 2012. A phased approach has been adopted with short-term goals to be achieved by the end of December 2004, medium-term goals to have been accomplished by the end of 2008 and long-term goals during 2009 and beyond. A project implementation plan (PIP) for the time period July 1999 to December 2004 has been developed for the Action Plan for Waste Treatment and Disposal. This implementation plan, detailing the main short-term activities, can be found in Annexure B.

Action Plans: Action Planning is the process, which defines the targets, methods, tasks, responsibilities, time frames, control procedures and the results expected for a specific activity or range of activities.

All Waste Disposal Facilities: All facilities used for the storage, handling or disposal of (solid) waste, including facilities controlled in terms of Section 20 of the ECA and facilities for the disposal of other wastes, such as building rubble, mining and coal combustion waste, but excluding effluent resulting from the use of water for industrial purposes and matter discharged into a septic tank or french drain system.

Coal Combustion Waste: Waste generated as a result of the combustion of coal, e.g. ash, resulting from activities at an undertaking for the generation of electricity under the provisions of the Electricity Act, Act No. 41 of 1987.

Co-disposal: Co-disposal is the mixing and joint disposal of Hazardous (H) and General (G) waste in the same landfill site. The co-disposal of general waste with hazardous waste as a means of facilitating disposal on a hazardous waste landfill site is acceptable in the short-term, whereas the co-disposal of any significant quantity of hazardous waste with general waste on a general waste landfill site is unacceptable.

End-of-Pipe Treatment: Treating pollutants at the end of a process, for example, by filters, catalysts and scrubbers, instead of preventing waste at the outset.

Hazardous Waste Disposal Site: A disposal site that is specifically designed for accepting hazardous waste. Sites are defined as H:H or H:h sites in terms of the DWAF Minimum Requirements (1998, 2^ND Edition).

Incineration: Incineration is both a form of treatment and a form of disposal. It is the controlled combustion of waste materials to a non-combustible residue or ash and exhaust gases, such as carbon dioxide and water.

Landfill: A waste disposal site controlled in terms of Section 20 of the ECA and used for the disposal of general municipal solid waste and/or the co-disposal of liquid or hazardous waste with dry general waste.

Polluter Pays Principle: Those responsible for environmental damage must pay the remediation costs, both to the environment and to human health, and the costs of preventive measures to reduce or prevent further pollution and environmental damage.

Section 20 Waste Disposal Facility: A facility that requires a permit in terms of Section 20 of the ECA, which is used for the storage, handling or disposal of waste controlled in terms of Section 20 of the ECA.

Waste: Waste is an undesirable or superfluous by-product, emission, or residue of any process or activity that has been discarded, accumulated or been stored for the purpose of discarding or processing. Waste products may be gaseous, liquid or solid or any combination thereof and may originate from domestic, commercial or industrial activities, and include sewage sludge, radioactive waste, as well as mining, metallurgical and power generation waste.

Waste Manifest: A waste manifest is a document that must be completed by the generator, the transporter and the disposer of hazardous waste. It is used to control the movement of these wastes to ensure that all loads are disposed correctly.