Towards Auditing Waste...

Adopted by the Eighth Meeting of the INTOSAI Working Group on Environmental Auditing

Towards Auditing Waste Management

Frontpage photo: Joe Cavanagh, NAOPrepress and printing: MacCompaniet asISBN 82-90811-41-1

At its 2001 meeting in Ottawa, Canada, the Working Group on Environmental Auditing (WGEA) of theInternational Organization of Supreme Audit Institutions (INTOSAI) adopted waste management as one ofthe central themes of its 2002-2004 Work Plan.

In 2002, at the first WGEA Steering Committee meeting in London, England, the Office of the AuditorGeneral of Norway presented a proposal for a background paper on waste management in support of SAIenvironmental audit activities. In January 2003, the first draft of the paper was discussed at the WGEASteering Committee meeting in Costa Rica. The Steering Committee’s comments were incorporated into thesecond draft that was presented at the eighth WGEA Assembly in Poland in June 2003 and approved as aformal WGEA document.

Toward Auditing Waste Management gives an overview of waste management issues and provides supremeaudit institutions (SAIs) with the information they need to conduct audits in this area. This paper is availa-ble on the WGEA Web site under WGEA Publications (www.environmental-auditing.org).

We would like to thank the Auditor General of Norway, Bjarne Mørk-Eidem, for having taken on this projectas well as the study team under the direction of Øivind Berg Larsen – Lillin Knudtzon, Sissel Iversen, AlfredMartinovits and Frank Ebbesen – for their dedicated work on the development and completion of the paper.We would also like to extend our thanks to the WGEA members and other SAIs for their contributions to thepaper.

We believe this paper will be a useful starting point for any audits of waste management.

Sincerely,

Sheila Fraser, FCAChair of the INTOSAI WGEA

Johanne GélinasAssociate Chair for the INTOSAI WGEA

3INTOSAI Working Group on Environmental Auditing: Towards Auditing Waste Management

Foreword

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Table of Contents

Executive summary .......................................................................................................... 7

0 Introduction ........................................................................................ 9

0.1 International awareness regarding waste .......................................................... 90.2 The INTOSAI WGEA recommends auditing waste ................................................ 90.3 Content and structure of this document ............................................................ 10

1 Background orientation on waste .......................................................... 13

1.1 What is waste? ................................................................................................ 131.2 Problems caused by waste .............................................................................. 131.3 Waste categories ............................................................................................ 141.4 Life cycle of a product ...................................................................................... 151.5 The waste stream ............................................................................................ 15

2 International agreements on waste ........................................................ 19

2.1 Delimitation .................................................................................................... 192.2 Agreements including non-hazardous/solid waste .............................................. 192.3 Agreements regarding hazardous waste ............................................................ 202.4 Agreements regulating radioactive waste .......................................................... 22

3 National waste management systems .................................................... 25

3.1 Radioactive waste management systems .......................................................... 253.2 Hazardous waste management systems ............................................................ 263.3 Solid waste management systems .................................................................... 28

4 How to determine focus for your waste audits ........................................ 31

4.1 Step 1 – Identify environmental and health risk scenarios .................................. 314.2 Step 2 – Map out the actors and their responsibilities ........................................ 324.3 Step 3 – Take account of the waste stream ...................................................... 334.4 Step 4 – Consider audit topics – choose focus .................................................. 36

5 Audits of waste management ................................................................ 39

5.1 Topic 1 – Existence of waste policy .................................................................. 395.2 Topic 2 – Compliance with national environmental policy .................................... 395.3 Topic 3 – Risk management .............................................................................. 425.4 Topic 4 – Quality of the implementation process ................................................ 455.5 Topic 5 – Performance of the system ................................................................ 465.6 Topic 6 – Compliance with national law .............................................................. 495.7 Topic 7 – Compliance with international obligations ............................................ 545.8 Topic 8 – Monitoring ........................................................................................ 565.9 Topic 9 – Effects of other government activities .................................................. 59

Appendix 1: Background Orientation on Waste ........................................................ 61

6 INTOSAI Working Group on Environmental Auditing: Towards Auditing Waste Management

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Appendix 2: Norwegian Radioactive Waste Management System .............................. 90Appendix 3: Canadian Radioactive Waste Management System ................................ 91Appendix 4: Canadian Hazardous Waste Management System ................................ 92Appendix 5: Canadian Non-hazardous Waste Management System .......................... 93Appendix 6: Chinese Waste Management System, excluding Radioactive Waste ........ 94Appendix 7: Norwegian Hazardous and Non-hazardous Waste Management System .. 96Appendix 8: Polish National Waste Management System ........................................ 97


Executive Summary

Waste is a major concern in all parts of the world

Contamination caused by waste is rated by theUnited Nations Environmental Programme as an en-vironmental issue that is important or critically im-portant in all areas of the globe. If waste is nothandled in a satisfactory manner, it poses greatdanger to the environment and the well-being andhealth of humans and animals. Radioactive wastecan be lethal and pollute large areas for centuries tocome. Medical waste can promote the possiblespread of diseases and infections. Hazardous wastemay cause illness and loss of life. Illegal dumpingand mismanaged landfills are unsightly and smelly,and they can contaminate soil and water. Burningwaste pollutes the air.

Pollution does not recognise national borders andthis has led to establishing of a number of internati-onal agreements. The international accords that arecurrently in force typically cover nuclear and hazar-dous waste and regulate the transboundary move-ment of waste.

Classification and handling of waste

Waste is a product that is no longer suited for its in-tended use. It may be worn out, or it may be an un-wanted by-product of a process. This definition goesfurther than the more intuitive one because it alsoincludes fully usable substances that are of no useto the present owner.

There are many ways of classifying waste. For the le-gislator, and thus for the SAI, the distinction bet-ween hazardous and non-hazardous waste may bethe most important because different regulationsusually apply to different types of waste. Specialkinds of hazardous waste include clinical/medicalwaste, electronic and electrical equipment, and radioactive waste. In this paper, the following maintypes of waste have been used in the presentation:solid, hazardous, and radioactive.

Different kinds of waste require different treatmentand final handling, due to both the physical and che-mical composition of the waste and the levels ofdangerousness. The composition will have an impacton the collection process and on whether the wastecan be used for energy-production, composting etc.

Public responsibility

The problems created by waste require practical so-lutions and policies. Countries regulate the handlingof waste with legal measures, and authorities at va-rious levels inspect and monitor the operations ofwaste generators, transporters and handlers.Nuclear and hazardous waste are often subject tomore stringent monitoring than solid waste.Individual citizens, especially in urban areas, do nothandle their own waste after the initial stages.Thus, it is important that the waste collection andtreatment services be conducted in a fair, effective,efficient, and environmentally sustainable manner.

Supreme Audit Institutions may play a key role in improvement of waste management

Supreme Audit Institutions (SAIs) are put in a uni-que role when it comes to auditing waste manage-ment. Deficiencies in a country’s waste manage-ment systems are a matter of national importanceand therefore of interest to the SAI. By exposing theinsufficiencies, the SAIs may help improve the qua-lity of waste management, and through this the nati-onal and international environment. This is alreadyrecognised, and during the years 1997–99 the INTOSAI members produced more than 100 audit reports on waste, in at least 49 different countries.In 2000, as many as 20 % of the SAIs reported thatthey were planning audits on waste in the next threeyears.

Choosing focus for the audits and getting started

For the SAIs that have not yet conducted audits onwaste, or for those that want to take a fresh look atthe issues, a four-step procedure is proposed. Instep one, it is recommended that environmental andhealth-risk scenarios be developed to determine theareas that have the highest materiality and risk.Then the various actors and their responsibilitiesshould be identified, pursuant to national and inter-national law. The responsible actors may differ withthe type of waste.

In searching for the most relevant audits, in stepthree, it is beneficial to analyse the waste stream,which identifies the eight stages that waste maypass through (prevention, generation, recycle/reuse/recover, collection, transport/export,


treatment/disposal, contaminated sites, and illegaldumping). For each stage in the waste stream, thereshould be policies and corresponding instrumentsdevised to handle it.

When focusing on which individual audits to per-form, the following generic audit topics and questi-ons are suggested:

• The existence of waste policy – are all stages ofthe waste stream covered by policy documentsand are these documents consistent with the ge-neral environmental policy?

• Compliance with national environmental policy –have the policies relating to waste managementbeen reflected in concrete terms in legislation/regulations?

• Risk management – are risks sufficiently mana-ged?

• Quality of the implementation process – are thepolicies implemented effectively? Are environ-mental impact assessments being carried out?

• Performance of the waste management system –are responsibilities delegated to appropriate bo-dies? Do the responsible agencies have the ne-cessary instruments? Are these instruments putto efficient use?

• Compliance with national laws and regulations –are the relevant actors complying with the natio-nal rules and procedures?

• Compliance with international obligations – arethe policies, legislation and practices in compli-ance with international obligations and agree-ments?

• Monitoring – are the necessary and required mo-nitoring systems in place and working efficiently?

• Effects of other government activities – are allgovernment activities managed according to thelegislation and regulations relating to waste ma-nagement?

The way forward in the audit of waste management

In 2001, the INTOSAI Working Group onEnvironmental Auditing decided to make "waste" asecond key theme. It also decided to continue thefocus on the original key theme of "water". Basedon the paper here presented, The Working Group re-commends that the Supreme Audit Institutions ofthe world consider auditing waste management andthe systems used to regulate and control this issuein the next work plan period (2005–07). This jointeffort will ensure a focus on this world scale pro-blem and will help to improve the environment.


Introduction

Waste is a continually growing problem, globally, regionally, and locally. The handling of waste, e.g.through incineration or landfills, usually leads to dis-charges into the soil, air, and water and is a sourceof global and local pollution. The problem is accele-rated by trends in consumption and production pat-terns and by the continuing urbanisation of theworld. The costs associated with the proper hand-ling of waste make it profitable to ignore waste treatment and to dispose of waste in a way that isdangerous to human health and the environment.Illegal dumping and unauthorised exports are exam-ples of criminal activities associated with the hand-ling of waste.

The problem has been given increased attention byinternational and national policy making bodies andcitizens.

0.1 International awareness regarding wasteAt the 1992 Rio Conference, waste was made oneof the priorities of Agenda 211 with specific atten-tion given to ensure the environmentally sound ma-nagement of toxic chemicals, including the preven-tion of illegal international traffic in toxic and dang-erous products, the environmentally soundmanagement of hazardous wastes, the environ-mentally sound management of solid wastes andsewage-related issues and the safe and environ-mentally sound management of radioactive was-tes.

At the Johannesburg World Summit on Sustainabledevelopment in 2002, the focus was on initiativesto accelerate the shift to sustainable consumptionand production, and the reduction of resource degra-dation, pollution and waste. The implementationplan was adopted by the Summit2, and has a para-graph (22) that states the priority to:

"Prevent and minimize waste and maximize reuse,recycling and use of environmentally friendly alterna-tive materials, with the participation of governmentauthorities and all stakeholders, in order to mini-mize adverse effects on the environment and im-prove resource efficiency, with financial, technicaland other assistance for developing countries. Thiswould include actions at all levels to:

(a) Develop waste management systems, with thehighest priority placed on waste prevention andminimization, reuse and recycling, and environ-mentally sound disposal facilities, including tech-nology to recapture the energy contained inwaste, and encourage small-scale waste-recy-cling initiatives that support urban and ruralwaste management and provide income-genera-ting opportunities, with international support fordeveloping countries;

(b) Promote waste prevention and minimization byencouraging production of reusable consumer goods and biodegradable products and develo-ping the infrastructure required."3

The world faces a number of major challenges to itsenvironment. In Global Environmental Outlook,4 theUnited Nations Environmental programme has as-sessed the relative importance of environmental is-sues within and across regions. A summary of thisassessment is reproduced in figure 1 (next page).

As can be seen the issue of urban and industrialcontamination and waste is rated to be critically important or important in all areas of the globe.

0.2 The INTOSAI WGEA5 recommendsauditing wasteAudits help raise awareness of the problems ad-dressed. Auditing waste management systems is away to help reduce the problems caused by waste in

0

1 Agenda 21 is a comprehensive plan of action to be taken globally, nationally and locally and was adopted by more than 178 Governments at the UNConference in Rio de Janeiro. (UN Sustainable Development web page http://www.un.org/esa/sustdev/agenda21.htm)

2 At the 17th plenary meeting on 4 September 20023 UN Report of the World Summit on Sustainable Development IU, Document A/CONF.199/20, p. 19. (http://www.johannesburgsummit.org/index.html)4 Global Environmental Outlook-1, United Nations Environmental Programme, Global State of the Environment Report 1997. (http://www.grida.no/geo1/exsum/ex3.htm)

5 Working Group of Environmental Auditing


a country by revealing the shortcomings of the ma-nagement system and the responsible actors andidentifying areas that need improvement.

Individual citizens, especially in urban areas, do nothandle their own waste all the way to final disposal.In most cases, specialised companies owned by oracting on behalf of the authorities do the handling.The monopoly inherent in this situation makes it es-sential that outside evaluators ensure that the ser-vice is provided in a fair, effective, efficient and envi-ronmentally sustainable manner.

The INTOSAI Working Group on EnvironmentalAuditing has had "water" as its key theme since1996. At its seventh meeting in Ottawa, Canada inSeptember 2001, the Working Group decided toadopt "waste" as a second key theme. In the thirdquestionnaire conducted by the Working Group, 65%of the Supreme Audit Institutions (SAIs) identifiedwaste as the most pressing environmental problemtogether with fresh water (also mentioned by 65%).

Based on the paper presented here, the WorkingGroup recommends that the Supreme AuditInstitutions of the world consider auditing waste ma-nagement and the systems used to regulate andcontrol this issue in the next work plan period(2005–07). This joint effort will ensure a focus onthis world scale problem and will help to improvethe environment.

0.3 Content and structure of this documentThe main objectives of this paper are to increaseknowledge about auditing waste management bysurveying different approaches to the problem andto inspire more audits in this field. The paper shouldhelp lower the threshold for commencing audits andencourage SAIs, with or without prior experience, toaudit various aspects of their country’s waste mana-gement. The paper contains a large selection of pro-blem areas that can be focused on, and it is ourhope that it will induce auditors to approach the au-dit of waste from new angles, and to prompt themany countries that have yet to do waste audits toget started in this important field.

Chapter one presents concepts and definitions rela-ted to waste and the environmental and health pro-blems caused by waste. The life cycle of a productand the stages that waste passes through in thewaste stream are discussed.

Chapter two presents the key international conventi-ons and standards related to waste, the most impor-tant of which is the Basel Convention on the Controlof Transboundary Movements of Hazardous Wastesand Their Disposal. Conventions regulating nuclearand non-hazardous waste are also presented.

Chapter three gives examples of the waste manage-ment systems in several different countries, and fo-

Figure 1: Relative importance of environmental issues within and across regions (Global State of the Environment Report 1997)

AfricaAsiaPacific

Europe &former USSR

LatinAmerica &Caribbean

NorthAmerica

West AsiaPolarRegions

Land: degradation

Forrest: loss, degradation

Biodiversity: loss, habitat fragmentation

Fresh water: access, pollution

Marine and coastal zones: degradation

Atmosphere: pollution

Urban and industrial: contamination, waste

Critically important Important Lower priority Negligible


cuses on how the structures of authority may be es-tablished at the national, regional and/or local level. The forth chapter of the paper discusses how to se-lect a focus for an audit of waste management foryour SAI. An approach, which includes a four-step-procedure, is presented.

In chapter five, the experiences gained in the INTO-SAI community from waste management audits arepresented. The problem areas from an audit view-point constitute the framework for the presentationof the audits. Financial, compliance, and perfor-mance audits are covered.

Appendix 1 provides a thorough background orienta-tion on this subject, including a presentation of im-portant problems related to waste, and a descrip-tion of waste-handling systems. Concepts and defini-tions related to waste are discussed.

Appendices 2–8 contain figures depicting organisati-onal charts of waste management systems inCanada, China, Norway, and Poland.

Leachate from sanitary landfill. Kiyoshi Okamoto, IDI

Jørgen Schytte / Samfoto


1.1 What is waste?The actual definition of waste can vary from countryto country, but most legal definitions of waste canbe summarised as a product or a substance that isno longer suited for its intended use. This definitiongoes further than the layman’s definition, which isoften restricted to something that no longer functi-ons properly. The legal definition often includes fully usable substances, but defines them as wasteif they are to be used in contexts other than theiroriginally intended one.

1.2 Problems caused by wasteMost countries recognise that environmentally soundwaste management is an issue of major concern. Forboth developing and developed countries, waste ma-nagement is an important factor in safeguarding hu-man health and environmental protection.

Unsatisfactory handling of waste can lead to thecontamination of soil, surface water, groundwaterand air. Some examples are:• Soil can be contaminated with toxic components,• Leachate7 from waste can pollute surface water

and groundwater

1 Background Orientation on Waste6

6 Much of this chapter is based on a report from the Norwegian Resource Centre for Waste Management and Recycling prepared for the Office of the Auditor General of Norway. More of the report is found in appendix 1.

7 Water that dissolves contaminants as it trickles through waste disposed of in a landfill. Leaching may result in hazardous substances entering surfacewater, ground water or soil.

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• Uncontrolled burning of waste produces toxicand carcinogenic gases

• Leaks of radioactive substances can contami-nate the air and soil

Furthermore, insufficient waste handling and emissi-ons can have negative impacts on public health,exemplified by:

• The transmission of diseases and infections byrodents, vector insects, etc.

• Birth defects caused by exposure to polluteddrinking water

• Cancer caused by radiation exposure• Respiratory problems caused by waste sorting,

uncontrolled burning of waste, etc.• Odour, littering, unsightliness, noise, etc.

Sanitation workers and people who come into directcontact with waste can also be directly affectedthrough skin contact. Cuts and bruises allow harm-ful substances to enter the blood stream, and thesesubstances can also enter the body through the di-gestion system if a worker’s personal hygiene is un-satisfactory.

1.3 Waste categoriesMany parameters can be used to describe and cate-gorise waste, and depending on your role with re-gard to waste, some will be more important than ot-hers. For a legislator, the distinction between hazar-dous and non-hazardous waste may be the mostimportant parameter, since legislation relating to ha-zardous waste is usually stricter than for non-hazar-dous waste. Likewise, the distinction is useful forauditors because the different legislation is usuallyaccompanied by different organisational structuresand different uses of policy instruments.

Non-hazardous waste is often called "solid waste".Waste in the form of powders, fluids, and gasses isconsidered hazardous regardless of its toxic proper-ties because it needs special handling to avoid un-wanted dispersal. Thus, all waste that is not included

under the classification of hazardous may be labelledsolid. Although not considered hazardous, solid wastecan cause considerable harm and damage, and maylead to diseases and air pollution and the poisoningof water sources for people and animals.

Hazardous waste poses a threat to human healthand the environment if it is not handled properly. Forthis reason, many countries have strict regulationsgoverning the storage, collection and treatment ofhazardous waste. Much hazardous waste originatesfrom industrial production.

Clinical/medical waste is a form of hazardous wasteand involves waste from the treatment of diseasesin humans and animals. This type of waste typicallyconsists of medicines, sharp objects, bandages,body fluids and body parts, and usually containsbacteria and other organisms that can spread harm-ful diseases if not properly handled.

Electronic and electrical equipment (EE waste) isanother type of hazardous waste. The materialsused in these products (PCB, lead, quicksilver, cad-mium and brominated flame-retardants) can causedamage if not treated properly. This type of wasteis relatively new and is rapidly increasing in disper-sal and quantity. Insufficient treatment of thiswaste will cause contamination of the soil, waterand air and may pose a special health risk for sani-tary workers.

The five symbols in figure 2 are examples of sym-bols that are used to designate products with hazar-dous properties.

Radioactivity is a hazardous property, because expo-sure to radiation can cause serious illness, or evendeath. Many radioactive substances are also highlytoxic. In general, radioactive materials are only avai-lable to scientists, nuclear power plants, and otherusers who have a specific need for radiation in theirwork. However, stolen or illegitimately sold nuclear/radioactive waste can be a potent weapon in thewrong hands and necessitates high alertness with

Figure 2: Examples of hazardous properties

Flammable Corrosive Toxic Ecotoxic Radioactive


regard to security. The management of radioactivewaste differs significantly from the management ofsolid and other hazardous waste. For this reason,radioactive substances are dealt with separately inthis paper.

Thus, we have the following main types of waste:solid, hazardous, and radioactive.

1.4 Life cycle of a productThe life cycle of a product is the process in whichraw materials are turned into products, consumed,and eventually discarded. Thereafter, the waste canbe reused, recycled, or disposed of. Although highlysimplified, the principles described below apply tomost products and waste, whether hazardous ornon-hazardous.

The chart in figure 3, depicts six phases in the lifecycle of a product:

In (1) raw materials or natural resources are manu-factured into products, which are eventually discar-ded (2).

(3) Shows reuse, while (4) depicts recycling. Reusemeans that a discarded product is reused in thesame way as it was used when it was a product. Ifan empty soda bottle is washed and filled with newsoda, that is called reuse, but if it is crushed, mel-ted, and used to produce windowpanes or wovenglass fabric, that is called recycling. Waste can alsobe used as a fuel, to generate energy (5).

In (6) waste is transformed into a natural resource,e.g. when food and/or organic matter is composted.At times (4) and (6) may overlap.

(7) Shows that some waste cannot be reused or re-cycled, leaving no choice but to dispose of it. Inmany cases, this means landfills with or withoutprior treatment, but destruction and/or incinerationwithout energy recovery are also regarded as meansof final disposal.

1.5 The waste stream As we have seen, each product has a lifecycle thatgenerates waste at a certain point in time. In figure3, the activities related to the products are depictedas arrows. In a corresponding figure based on thewaste stream, arrows might be used to indicate thedirection between the stages in which waste ishandled (figure 4, page 16). The dotted lines indi-cate illegal or unwanted occurrences.

Figure 4 shows the physical stages through whichwaste passes and is useful in order to gain anoverview of the waste management process. Thefirst stage in the waste stream is prevention. Theambition of preventing waste generation is linkedmore to waste policy than to actual waste hand-ling, but has a place in the waste stream nonetheless.

The second stage is the generation of waste. Typicalwaste generators are households, industry, hospi-tals, commercial businesses, and public entities.

Figure 3: Life cycle of a product

Raw Materials

(Natural) resources

Products

Energy

Waste

Final disposal

1

1

2

3

4

5

6

7


They generate different types of waste with regard tocomposition and substances.

The third stage of the waste stream covers thethree Rs: Recycle, Reuse and Recover. These areapproaches to waste treatment and may occur inter-nally within the activities of the waste generator (in-dicated with the direct arrow between Generationand the three R’s), or organised externally after thecollection and transport stages. Reusing and recy-cling are ways of recovering material. In addition,there is energy recovery and recovery of raw materi-als (composting).

There are several reasons for recovering as much ofthe waste as possible: it reduces the amount ofwaste sent for final disposal and thereby reducesthe need for transport and disposal; it makes use ofvaluable resources in the waste and thereby redu-ces the use of virgin raw materials.

The collection of waste is a stage that applies toonly some of the waste that is generated, depen-ding on the producers, and applies mainly to wastefrom households and small commercial businesses.This stage also includes the return of products tothe source. Producer Responsibility is a growing

trend and implies, for instance, that electricaland/or electronic devices with hazardous compo-nents (EE-waste) can be returned to the producer orto the shop that originally sold them.

Stage five is the transport and export of waste. Thewaste generators that are not users of the collectionof waste, such as large businesses, industries, andhospitals, need to transport their waste to a site forsafe treatment. The collected waste also needs to betransported. Some types of waste might be exported.Because of the special properties of hazardous waste,special precautions must be taken during collectionand transport, involving the training of the driver andco-driver, the types of packaging to be used, and thelabelling of the packaging and the transport vehicle.

The treatment and disposal of waste is stage six.Treatment and disposal often take place at thesame physical location, but may also be two (ormore) operations that require transport betweenthem. Nevertheless, this is the preferred end stationfor the waste, and secure handling here is of para-mount importance.

To reduce or eliminate the hazardous properties ofwaste, treatment is required. The two main approa-

Figure 4. The waste stream

Prevention

Generation

Collection

Transport, Export

Treatment, DisposalIllegal dumping

Contaminated sites

Recycle, Reuse, Recover

1

2

4

5

6

3

7

8


ches are thermal destruction (conversion into harm-less components at high temperatures) and chemi-cal treatment (such as the stabilisation of mercury

by converting it to a sulphide). Neutralisation is anoption in the treatment of acids and alkalis. Whenmixed in the right proportions acids and alkalis neu-tralise each other, and the products of this processare often relatively harmless.

Disposal at landfills is the most common solutionfor handling either all of the waste or the residualwaste that cannot be treated as a part of otherwaste-processing methods, such as composting, incineration, recycling etc. There is a wide range oflandfills varying from open, uncontrolled dumps tosanitary landfills that are a fully acceptable environ-mental solution. The main differences are in the waythey are operated and the level of adverse environ-mental effects they produce.

Sometimes the waste is illegally dumped, and thatconstitutes stage seven. Illegal dumping may occurat waste disposal sites, on private or public land orin the sea. This may involve the large-scale dumpingof inert wastes, such as medical waste or chemi-cals, or litter in the form of small quantities of non-hazardous waste.

Recycling project. Curt Carnemark / Mira / Samfoto

Operator hoists waste in an incineration. Sigmund Krøvel-Velle / Samfoto

Illegal dumping of waste will often result in stageeight – contaminated sites. Likewise, if the disposalof waste is not conducted properly the result will becontaminated sites. These sites may still be in useor they may have been used for dumping of waste atsome earlier time.

At each of these eight stages, the government mayintervene to ensure sound management. A goodwaste policy should include all of the stages throughwhich waste passes. The waste stream determinesthe premises for an audit of waste management, aswe will return to, in chapter 4.


Tanks of chemicals for shipping by boat labelled with signs. A numeric code indicates the contents. Espen Bratlie / Samfoto


2 International Agreements on Waste

The environment is of global interest and importance.Pollution does not recognise national borders and istransported freely between countries and continents.The international community has recognised this fact,and a number of attempts to improve the environ-ment have been recorded in ink during the last fewdecades. The most relevant of these agreements re-garding waste will be presented below. These may beregarded and used as a source of audit criteria whenauditing waste and waste management systems.

Relevant Internet sites and the Yearbook ofInternational Co-operation on Environment andDevelopment8 are used as sources in this presenta-tion, and give more details and references to agree-ments on environment and development.

2.1 Delimitation Waste can constitute a raw material when recycledand reused. Scrap metal is typically used for newconstruction. Using this line of reasoning, a specifictype of waste may be defined as a "product" or a"good" and thus come under the jurisdiction of theWorld Trade Organization (WTO). This may be oneway of circumventing the strict regulations laid downregarding waste and relegating it to the sphere oftrade regulations. Although this paper does not in-clude trade agreements, auditors should bear inmind that they may nevertheless be relevant as asource of audit criteria.

2.2 Agreements including non-hazardous/solid wasteLegislation concerning waste is usually differentia-ted according to the type of waste. Internationalconventions often cover nuclear and hazardouswaste, whereas non-hazardous waste, often calledsolid waste, is more usually regulated at the natio-nal level. However, there are a few international con-ventions that also cover non-hazardous waste.These are presented below.

2.2.1 The OECD decision C(2001)107/FINAL9

The Organisation for Economic Co-operation andDevelopment (OECD) has instituted binding agree-ments for its member countries (30 states) regula-ting the transboundary movements of waste desti-ned for recovery operations.

Between 1984 and 1992, eight OECD Council Actswere adopted covering waste identification, definition,and control of transboundary movements of waste.Seven of these Acts are currently being consolidatedand updated10 with the ultimate goal of developing aglobal control system for waste movements.

The control system aims to facilitate the trade of re-cyclables in an environmentally sound and economi-cally efficient manner by using a simplified proce-dure and introducing a risk-based approach to as-sessing the necessary level of control of materials.Waste exported to countries outside the OECD area,whether for recovery or final disposal, are not sub-ject to this simplified control procedure.

The OECD control system is based on two types ofcontrol procedures:

• Green Control Procedure: for waste that poses a minor threat to human health and the environ-ment and are consequently not subject to any other controls but those normally applied in commercial transactions

• Amber Control Procedure: for waste that poses asufficient risk to justify their control.

The relevant national authorities and customs offi-ces carry out the control of waste shipments whenappropriate with notification and movement docu-ments.

2.2.2 London Convention11

The London Convention on the Prevention of MarinePollution by Dumping of Wastes and Other Matter isa global agreement that was drawn up at the Inter-

8 Yearbook of International Co-operation on Environment and Development 2002/2003, London, Earthscan Publications Ltd, London. Home page http://www.greenyearbook.org

9 The OECD home page: http://www.oecd.org10 OECD Council Act [C(2001)208]11 The London Convention home page: http://www.londonconvention.org


Governmental Conference on the Dumping ofWastes at Sea in London in 1972. The Conventionentered into force in 1975. The objective of theConvention is to prevent pollution of the sea by thedumping of waste and other matter that is liable tocreate hazards to human health, to harm living re-sources and marine life, to damage amenities or tointerfere with other legitimate uses of the sea12.

In 1993, parties started a detailed review of theLondon Convention. This review was completed withthe adoption of the 1996 Protocol to the LondonConvention 1972, which, when entered into force,replaces the London Convention. By 31 May 2002,there were 78 Parties to the convention.

2.2.3 The MARPOL Convention13

The MARPOL Convention for the Prevention ofPollution from Ships is the main international con-vention covering prevention of pollution of the ma-rine environment by ships from operational or acci-dental causes. It is a combination of two treatiesadopted in 1973 and 1978 and has been updatedby amendments over the years. The Convention wasadopted in 1978 at the International MaritimeOrganization (IMO). It entered into force in 1983.The key objectives of the Convention are:

• To eliminate pollution of the sea by oil, chemi-cals, harmful substances in packaged form, se-wage, garbage and other harmful substances thatmight be discharged in the course of operations;

• To minimise the amount of oil that could be re-leased accidentally by ships, including also fixedor floating platforms.

• To improve further the prevention and control ofmarine pollution from ships, particularly oil tan-kers14 .

By 31 May 2002, there were 121 Parties to theConvention. Thirty-five states have made exceptionsfor some of the annexes.

2.3 Agreements regarding hazardous wasteIn the late 1980s, a tightening of environmental re-gulations in industrialised countries led to a drama-tic rise in the cost of hazardous waste disposal.Searching for cheaper ways to get rid of this type ofwaste, "toxic traders" began shipping hazardouswaste to developing countries and to Eastern

Europe. Once this was discovered, internationalwork was started to restrict these activities.

2.3.1 Basel Convention15

The Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and TheirDisposal is a global agreement addressing the pro-blems and challenges posed by hazardous waste.The key objectives of the Basel Convention are to mi-nimise the generation of hazardous waste in terms ofquantity and hazardousness, to dispose of them asclose to the source of generation as possible and toreduce the movement of hazardous waste. By 1 July2002, there were 151 Parties to the Convention.

During its first decade (1989-99), the Conventionwas principally devoted to setting up a frameworkfor controlling the transboundary movements of ha-zardous waste, that is, the movement of hazardouswaste across international frontiers. It developed cri-teria for "environmentally sound management". A control system, based on prior written notification,was also put into place.

Environmentally sound management (ESM) is a cen-tral goal and means taking all practical steps to mini-mise the generation of hazardous waste and strictlycontrol its storage, transport, treatment, reuse, recy-cling, recovery, and final disposal, for the purpose ofprotecting human health and the environment.

One of the guiding principles of the BaselConvention is that, in order to minimise the threat,hazardous waste should be dealt with as close towhere it is produced as possible. Therefore, underthe Convention, transboundary movements of hazar-dous waste or other waste can take place only uponprior written notification by the state of export to thecompetent authorities of the states of import andtransit (if appropriate). Each shipment of hazardouswaste or other waste must be accompanied by amovement document from the point at which atransboundary movement begins to the point of dis-posal. Hazardous waste shipments made withoutsuch documents are illegal.

During the coming decade (2000–10), the Conventionwill build on the framework from 1989–99 by emphasi-sing full implementation and enforcement of treatycommitments. The other area of focus will be the mini-misation of hazardous waste generation. Recognisingthat the long-term solution to the stockpiling of hazar-

12 London Convention, Article 1 13 International Maritime Organization (IMO) home page, http://www.imo.org/home.asp 14 Yearbook of International Co-operation on Environment and Development 2002/2003, Earthscan Publications Ltd, London, page 12315 This summary and the paragraph above are extracts from the home page of the Basel convention; http://www.basel.int


dous waste is reduction of the generation of thatwaste – in terms of both quantity and hazardousness– a ministers’ meeting in December 1999 set out gui-delines for the Convention’s activities during the nextdecade, including:

• active promotion and use of cleaner technolo-gies and production methods

• further reduction of the movement of hazardousand other waste

• the prevention and monitoring of illegal traffic• improvement of institutional and technical

capabilities – through technology when appropri-ate – especially for developing countries andcountries with economies in transition

• further development of regional and sub-regionalcentres for training and technology transfer

The guidelines for the Convention’s activities led tothe Draft Strategic Plan. The plan takes into accountexisting regional plans, programmes or strategies,

the decisions of the Conference of the Parties andits subsidiary bodies, ongoing project activities andprocess of international environmental governanceand sustainable development.

The Basel Convention contains specific provisionsfor the monitoring of implementation and compli-ance. A number of articles in the Convention obligeparties (national governments that have acceded tothe Convention) to take appropriate measures to im-plement and enforce its provisions, including mea-sures to prevent and punish conduct in contraven-tion of the Convention.

2.3.2 Bamako and Waigani Conventions 16

The Basel Convention has clear links with regional ha-zardous-waste regimes, in particular the 1991Bamako Convention (which came into force in 1998)and the 1995 Waigani17 Convention (which came intoforce in 2001). The Bamako Convention prohibits the

Transport of chemicals on a ferry. John Petter Reinertsen / Samfoto

16 Yearbook of International Co-operation on Environment and Development 2001/2002, Earthscan Publications Ltd, London, page 4717 For more information about The Waigani Convention see; http://sprep.org.ws


import of hazardous waste into Africa, and theWaigani Convention prohibits the import of hazardouswaste into Pacific Island developing countries. Theseregional regimes were partly established in responseto the initial failure of the Basel Convention to ban ex-ports from North to South. The Basel Secretariat co-operates with the secretariats of these regional regi-mes and shares knowledge about institutional proce-dures and functions. These regional agreements mayalso assist national implementation of environmen-tally sound waste management strategies.

2.4 Agreements regulating radioactive wasteRadioactive waste is in an exceptional position, andcan be fatal if not handled properly. Despite thisfact, which is generally acknowledged, there is stillno wi-dely endorsed convention that explicitly addres-ses the issue of nuclear waste. More states have

ratified the general convention that states precautio-nary principles regarding nuclear management.

2.4.1 Joint Convention

The Joint Convention on the Safety of Spent FuelManagement and on the Safety of RadioactiveWaste Management18 was the first legal instrumentto address these issues directly on a global scale. Itentered into force on 18 June 2001. The objectivesof this Convention are:19

• To achieve and maintain a high level of safetyworldwide in spent fuel and radioactive wastemanagement, through the enhancement of nati-oal measures and international co-operation, in-cluding safety-related technical co-operationwhere appropriate

• To ensure that during all stages of spent fuel andradioactive waste management there are effec-tive defences against potential hazards so that

Handling of radioactive waste. Kjeller.

18 IAEA home page; http://www.iaea.org19 Joint Convention, chapter 1, article 1


individuals, society and the environment are pro-tected from the harmful effects of ionising radia-tion, now and in the future, in such a way that theneeds and aspirations of the present generationare met without compromising the ability of futuregenerations to meet their needs and aspirations

• To prevent accidents with radiological conse-quences and to mitigate their consequencesshould they occur during any stage of spent fuelor radioactive waste management

By 26 November 2002, there were 29 Parties to theConvention.

The Joint Convention applies to spent fuel and radio-active waste resulting from civilian nuclear reactorsand applications and to spent fuel and radioactivewaste from military or defence programmes if andwhen such materials are transferred permanently toand managed within exclusively civilian program-mes, or when declared as spent fuel or radioactivewaste for the purpose of the Convention by the con-tracting party. The Convention also applies to plan-ned and controlled releases into the environment ofliquid or gaseous radioactive materials from regula-ted nuclear facilities.

The obligations of the contracting parties with respectto the safety of spent fuel and radioactive waste ma-nagement are based to a large extent on the princi-ples contained in the International Atomic EnergyAgency (IAEA) Safety Fundamentals document "ThePrinciples of Radioactive Waste Management", pu-blished in 1995. They include, in particular, the obli-gation to establish and maintain a legislative and re-gulatory framework to govern the safety of spent fueland radioactive waste management and the obliga-tion to ensure that individuals, society, and the envi-ronment are adequately protected against radiologicaland other hazards. This can be done by appropriatesiting, design and construction of facilities and by making provisions for ensuring the safety of facilitiesboth during their operation and after their closure,etc. The Convention imposes obligations on contrac-ting parties in relation to the transboundary move-ment of spent fuel and radioactive waste based onthe concepts contained in the IAEA Code of Practiceon the International Transboundary Movement ofRadioactive Waste. In addition, contracting partiesare obligated to take appropriate steps to ensure thatdisused sealed sources are managed safely.

2.4.2 Convention on Nuclear Safety20

The Convention on Nuclear Safety is a global agree-ment that was adopted in Vienna in 1994. Its aim isto legally commit participating states that operateland-based nuclear power plants to maintain a highlevel of safety by setting international benchmarksto which states would subscribe. The Convention en-tered into force in 1996.

In the Preamble, the Convention states that the con-tracting parties affirm the need to begin promptlythe development of an international convention onthe safety of radioactive waste management assoon as the ongoing process to develop waste ma-nagement safety fundamentals has resulted inbroad international agreement.21

The Convention is an incentive instrument. It is notdesigned to ensure fulfilment of obligations by par-ties through control and sanctions, but is based ontheir common interest in achieving higher levels ofsafety, which will be developed and promotedthrough regular meetings of the parties.

The specific safety obligations in the Convention arebased on what are termed "fundamental safety pro-visions" rather than on highly detailed standards;guidance on the more detailed internationally agreedsafety standards are already available, and theseare continually being updated. Yet the Conventionalso includes a series of more detailed obligations.With regard to waste, article 19 of the Conventionstates:

• Contracting Party shall take the appropriatesteps to ensure that the generation of radioac-tive waste resulting from the operation of a nu-clear installation is kept to the minimum practi-cable for the process concerned, both in activityand in volume, and any necessary treatment andstorage of spent fuel and waste directly relatedto the operation and on the same site as that ofthe nuclear installation take into considerationconditioning and disposal

By 12 April 2002, there were 53 Parties to theConvention. For more information about relevant international agreements on nuclear issues see thehome page of the IAEA22.

20 IAEA home page; http://www.iaea.org 21 The Convention on Nuclear Safety, preamble viii22 http://www.iaea.org

Transport of radioactive waste. Bellona.


3 National Waste Management Systems

All countries experience waste-related problems.These problems require policies and practical soluti-ons. A lack of policy in an area may lead to inade-quate regulations, which can, in turn, result in ran-dom practices that may be harmful or even dange-rous. The solution is a complete managementsystem.

In connection with the establishment of manage-ment systems for waste, it is important to take ac-count of the fact that the different kinds of wastecan require different systems. Following the catego-risation in Agenda 21, radioactive waste, hazardouswaste and non-hazardous waste are often manageddifferently. This has direct implications for how a SAIcan audit the waste management system, becausedifferent levels of authority may be responsible forthe management or regulation of the different typesof waste.

Laws regulating radioactive waste are usually deter-mined at the national level. Hazardous waste is alsomost often regulated at the national level, whereasnon-hazardous waste is regulated at the regional orlocal levels in many countries. This in turn has impli-cations for the feasibility of a SAI carrying out an au-dit. Whereas some SAIs have a mandate to audit alllevels of administration, many SAIs are limited to fi-elds regulated by national (and international) legisla-tion. All audit activities should be within the SAI’saudit mandate.23

The SAIs’ possibility of auditing waste managementtherefore depends on structures of responsibility atthe national, regional and/or local level. Drawing onthe national waste management systems currentlyused in Poland, China, Canada and Norway, essen-tial elements in waste management systems will bepresented. The presentation is differentiated accor-ding to type of waste, e.g. management of radioac-tive, hazardous and solid waste. The completeexamples from the different countries are presentedin appendices 2 to 8.

3.1 Radioactive waste management systems

Most countries have legislation for radioactive and nuclear waste at the national or federal level. The legislative body thus governs the management of radio-active and nuclear waste and provides agencies withregulatory authority. The agencies that manage radio-active waste are usually at the national level, makingthem natural targets for scrutiny by SAIs.

Radioactive waste is usually divided into two catego-ries: low-level waste and high-level waste, where thelatter has a much longer life expectancy. High-levelwaste consists in the main of spent nuclear fuel.Low-level waste consists of residues from past in-dustrial processes, contaminated material createdby power plants or institutions, medical waste, andwaste from uranium-mining processes.

As a country that mines and uses radioactive sub-stances, Canada has long had mechanisms to con-trol radioactive waste24. Canada practises the princi-ple that the owners or generators of the nuclearwaste (with the exception of historic waste) are re-sponsible for the final disposal.

A number of federal agencies and departments orministries share the responsibility for the differentfunctions that need to be covered in connection withradioactive waste. The following description high-lights the functions rather than the actual names, inorder to focus on the purpose of the organisation.

An independent agency of the Government of Canadais responsible for regulating the nuclear industry,granting licences to nuclear facilities, carrying out en-vironmental assessments in collaboration with anagency specialised in assessments, and workingwith the Ministry of Transportation to regulate safetransport of nuclear waste across the country.

A designated office is responsible for the establish-ment of national policies for low-level waste mana-gement. It offers a disposal service (user-paid), car-

23 INTOSAI Auditing Standards Paragraph 1.0.3424 Information found on the UN page presenting Agenda 21: http://www.un.org/esa/agenda21/natlinfo/index.html


ries out the clean-up and remediation of historicwaste and uranium tailings, and provides supportfor clean-up and planning.

Another governmental organisation offers its servi-ces to each nuclear energy corporation for the ma-nagement of high-level nuclear waste disposal. Thisorganisation reports to the Minister of NaturalResources.

Finally, there is a federal corporation that serves asan international nuclear technology and engineeringcompany. Its responsibilities include managing mostof the nuclear low-level waste programmes inCanada, owning and operating some nuclear facili-ties, conducting research and receiving reports fromthe waste management organisations.

The producers of high-level nuclear waste in Canadaare mainly the provincially-owned power generators.

In Poland, the problem of radioactive waste is of mi-nor importance because there are no nuclear powerplants. The principles of handling radioactive materi-als are nonetheless regulated in an act of law andits executive regulations. These regulations esta-blish conditions under which the purchase and pos-session of radioactive materials are possible and li-kewise their storage and transport (including tran-sit). They also establish conditions for the location,construction and supervision of nuclear buildingstructures, laboratories, institutions using radioac-tive material, etc.25.

In a country like Norway, which has only limitedquantities and easily traceable uses of each type ofradioactive waste, one ministry is responsible for allaspects of the management of radioactive waste. A governmental agency regulates the use of radio-active substances and fissile material, provides theprofessional basis for decisions regarding licencesfor the operation and construction of facilities underthe Ministry of Health, and oversees and conductsinspections and monitoring.

3.2 Hazardous waste management systemsHazardous waste is usually regulated at the nationallevel, but in some countries a regional or provincialauthority may be in charge. The national legislationmay provide for more detailed regulations and activi-ties at the regional or local level, such as inspection

and monitoring. If local or regional authorities are re-sponsible for some activities, this may make it moredifficult for SAIs with mandates on a national levelto audit them.

In Canada, the federal government’s responsibilityfor hazardous waste is mainly limited to the trans-port of waste. The provincial/territorial authoritiesare primarily responsible for managing hazardouswaste within provincial/territorial borders, includingdevising complementary legislation to that at the fe-deral level and issuing permits to disposal facilities.At the local level, authority is delegated to municipa-lities by provinces and territories using legislation,bylaws and boards of health. The local level mayoperate or contract out final destinations for waste(i.e. landfills and treatment plants). The bottom-lineresponsibility for the actual correct handling of thehazardous waste still lies with the producer of thewaste and the operator and/or owner of the wastedisposal site once the waste has been transportedthere.

Although the federal level in Canada has limited re-sponsibility for hazardous waste, there is some fe-deral activity and several actors may be involved.

The Ministry of Transportation works with theMinistry of the Environment to control the movementof hazardous waste throughout Canada and acrossits borders. The Ministry of the Environment is re-sponsible for implementing waste manifest sys-tems, operating notification systems for waste cros-sing international boundaries, maintaining liaisonson international transport with provinces and territo-ries, and ensuring compliance with legislation.

The Ministry of the Environment manages and dispo-ses of hazardous waste generated by federal facili-ties on federal lands, controls ocean dumping andco-ordinates the waste management activities of thefederal government through the operation of aWaste Management Branch.

The Ministry of Fisheries and Oceans in Canada en-sures compliance with the Fisheries Act to preventdeleterious substances from entering fish habitats.

A council of ministers serves as an intergovernmen-tal forum for debate on hazardous waste issues.The council established a Hazardous Waste TaskGroup to work towards the creation of a nationallyharmonised system for managing hazardous waste

25 Information found on the UN page presenting Agenda 21: http://www.un.org/esa/agenda21/natlinfo/index.html.


and hazardous recyclable materials by developingguidelines for various treatment facilities, such asincineration and physical-chemical-biological treat-ment. On request from the Ministry of theEnvironment, this group also provides advice onwhether to develop or update regulations regardinghazardous waste.

In several countries, different legislation regulatesdifferent types of waste, but this is not necessarilymirrored in the organisational structure. For in-stance, in China the same organisational structureapplies to both hazardous and non-hazardouswaste.

The Chinese National People’s Congress (the legis-lative body) discusses and votes on draft laws andrelevant bills, examines and approves the NationalEconomic and Social Development Plan, and moni-tors and inspects the execution of environmentallaws by government departments. The State Council(the central government) issues relevant administra-tive regulations, mandates the National General

Plan of Environmental Protection and implements re-levant laws, rules and policies.

The responsibilities are further divided among threegovernment bodies. The State Environmental

Hospital waste – syringes. Bente S. Meen, OAG Norway

Bente S. Meen, O

AG N

orway


Protection Agency conducts nationwide monitoringof the management of waste, issues administrativerules, systems and standards, sets standards forenvironmental quality and waste discharge, and or-ganises the implementation of relevant rules, sys-tems and regulations. The State Economic andTrade Commission manages the use of recycled re-sources and co-ordinates environmental protectionby industry and the development of industries rela-ted to environmental protection. The Ministry ofConstruction directs and monitors the constructionof urban infrastructures and monitors and managesdisposal of urban household waste.

These three government bodies all have a set of lo-cal counterparts. In China, there are three levels oflocal government: Province (Autonomous Region,Central Municipality), City and County. A local go-vernment agency is under the governance of the re-spective level of local government and under theprofessional guidance of the respective governmentagency at the next higher level.

The local governments of China have the followingresponsibilities:The local environmental protection agencies inspectand manage waste disposal work in the local regi-ons, issue relevant rules and guidelines concerningenvironmental protection, set local environmentalstandards, and organise the execution of relevantregulations, rules and mandates.

The local economic and trade commissions managethe comprehensive use of recycled resources andco-ordinate environmental protection and the deve-lopment of industries related to environmental pro-tection in their respective local regions.

The local environmental sanitation agencies directsand monitor the construction of environmental pro-tection facilities and monitor and manage the dispo-sal of urban household waste in their local regions.

Different local government bodies regulate the acti-ons of the waste producer depending on whetherthe waste producer is an industry or other commer-cial producer or a household/small business.Households are obligatory users of municipal wasteservices and are subject to management by the lo-cal agency of environmental sanitation and the localEconomic and Trade Commission. Industrial enter-prises are responsible for their own waste under themonitoring of the appropriate government bodies,namely the local environmental protection agencyand the local economic and trade commission.The same division of responsibility according to

waste producer is found in the Norwegian system. If the producer of hazardous waste is an industry,then the government control and licensing body isinvolved. This agency provides the professional ba-sis for decisions made by the Ministry of theEnvironment on pollution issues, issues licences toindustrial and treatment plants, monitors activitiesand conducts inspections. By contrast, if the hazar-dous waste originates from a household, the munici-pality is obligated to provide the household with ameans of disposal.

3.3 Solid waste management systemsIn Poland, the Ministry of the Environment is re-sponsible for general aspects related to waste management, and draws up, and co-ordinates theState Ecological Policy and implements executiveprogrammes of the National Waste ManagementPlan. The State Inspection for EnvironmentalProtection co-ordinates and draws up national auditprogrammes on compliance with environmental re-gulations and on national environmental-monitoringprogrammes.

The more direct management of solid waste is car-ried out at the regional level. The regional manage-ment board draws up regional environmental-protec-tion programmes, including management program-mes. The corresponding regional agency issueswaste-management permits and concessions to in-dustrial plants that do not have a significant impacton the environment. The regional inspectorate forenvironmental protection runs the waste manage-ment monitoring system and performs audits of implementation of statutory regulations.

On the local level in Poland, a County ManagementBoard draws up environmental protection program-mes, including local waste management plans, andissues waste management permits for other indus-trial plants that do not have a significant impact onthe environment.

In China, solid waste is subject to the same regula-tory system as hazardous waste. The waste from in-dustry is under the supervision and regulation of thelocal environmental protection agencies and the lo-cal economic and trade commissions. Householdsolid waste is managed by the local environmentalsanitation agencies and the local economic andtrade commissions.

Likewise, in Norway, household waste is managedat the local level, whereas industrial waste is mana-ged at the national level, regardless of whether it is


solid or hazardous waste. In some countries, thewaste generated by commercial activities may alsobe handled by the municipal or local waste disposalsystems.

In Canada, most of the activities related to non-ha-zardous waste management are regulated at regio-nal level by the provinces and territories. These bo-dies or agencies issue certificates of approval (per-mits) to operate waste disposal sites, which definethe types of waste the facility can accept and theconditions for environmentally sound waste-dispo-sal. All waste-disposal sites must have a permit andcomply with its conditions for operating. The agen-cies develop a waste-exchange programme (policy,not a legislated requirement), which is a databaselisting waste generators and the types and quanti-ties of waste materials produced, so potential usersof waste products can contact them to reuse or re-cycle their waste. Furthermore, the agencies or regu-lating bodies legislate off-site recycling programmesthat divert recyclables from the waste stream to re-cycling facilities (paper products, ferrous metals,construction and demolition materials, etc.). Theauthority is delegated to municipalities using legisla-tion, bylaws and boards of health.

The municipal or local level in Canada providessome waste management services or oversees thecontracting out of specific services (e.g. residentialcurb-side waste collection), may operate waste dis-posal facilities and may operate centralised pro-grammes and facilities for composting organic mate-rials.

The private sector in Canada does most of the col-lection and transportation of waste and recyclablesand may operate disposal facilities, transfer stati-ons and recycling facilities.

The waste management industry or the private sec-tor may be included in a comprehensive solid-wastemanagement system. They may perform services forcommercial/industrial waste generators and/or maywork on contract, performing services for the localwaste management authority (collection, transfer/re-cycling plants, and final treatment of the waste). Animportant framework for this industry is thereforethe national and local waste policies, since thesecan serve as a basis for improvements and invest-ment in waste management systems.

Trygve Bølstad / Samfoto


4 How to Determine Focus for YourWaste Audits

In this chapter, we will suggest an approach foridentifying the most pressing areas on which to con-duct waste management audits.

This is a four-step procedure, starting with identify-ing the risks entailed by waste in a country. The nextstep is mapping out the relevant actors and their re-sponsibility. The third step is taking the wastestream into account, and the final step is choosinga focus for the audits after the consideration of au-dit topics.

4.1 Step 1 – Identify environmental and health risk scenariosAuditing is usually about financial risks. In environ-mental auditing, risks to health and the environmentare prime concerns.

The first step in the planning of waste audits con-sists of creating risk scenarios by identifying themain problem areas related to waste in the countryand the risk they pose for public health and the envi-ronment. This exercise will give a picture of thedanger the waste entails. If there are serious pro-blems at basic levels of waste handling, we arguethat this is of national importance and thereforepossible for the SAI to address in order to raise con-sciousness about it.

Issues that are shared by neighbouring countriesshould be considered, and it should be possible forSAIs to co-operate in identifying the main problemareas within a region.

Good descriptions of the problems related to wasteand the specific problems a certain country may en-counter may already exist and be available in whitepapers or other documentation created by a Ministryof Environment or other responsible departments oragencies in the country. If no such descriptionexists it may be the responsibility of the SAI to pointthis out to the relevant authority.

4.1.1 Assess the seriousness of the possible damage from waste

The seriousness of damage from waste relates toboth people and the environment. For people, it may

be divided in two aspects: the number of peoplewho may be affected and the severity of the harmthey may suffer. Dispersal is an important factor re-lated to the number of people who may be affected.Harmful chemicals and biological waste are most wi-dely dispersed by water and air.

When determining the seriousness of damage to theenvironment, reversibility is a key factor. If the da-mage is irreversible, it is especially grave. Habitat isanother important dimension for environmental da-mage. Some species live in, breed in or passthrough a few and restricted areas, and may be-come extinct if these crucial areas are polluted.

When considering risks, the acuteness of thedanger is also essential. The acute threats need tobe addressed first. When these are under control, itis equally important to prevent future acute situati-ons. Foreseeing and preventing potential crises wellin advance is better than having to solve them afterthey have occurred.

Three examples related to the different types ofwaste illustrate the point about seriousness.

Example I: Radioactive waste has a huge damagepotential. If released it can contaminate a largenumber of people, and the injury can be very seri-ous. All parts of the natural environment will be da-maged, and the damage may persist for years.

Example II: Hazardous waste may be highly toxicand flammable, even explosive. The damage it maycause to all living organisms if poisonous substan-ces are released into water is obvious. Fires set byflammable substances may release toxins into theair, burn down large areas and kill people and all other living organisms in the area.

Example III: Solid or non-hazardous waste may contaminate drinking water through leachate or flooding. If close to a large water source, this mayaffect millions of people.

Obviously the seriousness of the possible damagecaused by poorly handled waste is not dependenton the type of waste. To determine a country’s most


serious waste problem the probability of damagemust also be considered.

4.1.2 Detect the probability of damage from waste

The inherent and/or potential danger of each type ofwaste is realised if the waste handling is inade-quate. This can be illustrated from the examplesabove. If solid waste is placed indiscriminately indumps near water sources and flooding rivers, therisk of contamination of the water will be high. Ifdumps are located far from water and people, theimmediate risks for public health will be lower. If so-lid waste is burned at incinerators that have equip-ment for purifying the emissions, the risks of da-mage to health and the environment will be low.

Hazardous waste needs to be handled in compliancewith strict quality requirements. The waste generatorshould be obliged to manage the waste. Treatmentprocedures such as thermal destruction, neutralisa-tion or physical stabilisation should be in place, andthe vehicles that transport this waste must be con-structed for this purpose. Storage sites should besafe. If this is not the case, basic safety require-ments will not have been met, and the auditorshould seek to find a way to get management andpoliticians to focus on these dangers.

Radioactive waste is potentially the most dangerouswaste because it can kill all organisms and be long-lived. In most countries it is handled by a smallnumber of actors and restrictions are tight. Usuallythe systems relating to radioactive waste are of highquality, but small faults in the systems can havegrave consequences, and so the requirements forthe systems must be high.

For all types of waste, there is also a risk of criminalbehaviour. Industries, landfill operators and otherswho are obliged to handle waste and do it safely,may find solutions that are cheaper but less secure.When considering the risk picture, a SAI should con-sider the likelihood that this may occur.

4.2 Step 2 – Map out the actors andtheir responsibilitiesThe second step is to create an overview of the or-ganisational structure of the waste managementsystem. Most likely, there will be different systemsfor radioactive, hazardous and solid waste. Thisoverview should include the most important actors:

authorities at the national, regional and local levels,the waste generators and other actors that maypose a risk through their handling of waste. The organisational structure for waste managementmay vary considerably among different countries,but most of the systems have certain functions thatneed to be fulfilled. It is necessary to map out theappropriate authorities to identify the relevant enti-ties that should be audited. The responsible govern-ment bodies and the nature of the accountability re-lationships between the different actors should beidentified.

Most countries have a legislative body responsiblefor formulating environmental policies and enactingappurtenant laws. International agreements providedirections for the national legislative work. In manycountries one government authority, usually calledthe Ministry of the Environment, is responsible forall of the environmental policy at the federal or nati-onal level, including the management of waste. Inother countries, several ministries are responsiblefor different parts of the waste management sys-tem. In these countries, it is important to map outwhich parts of the policy each ministry is responsi-ble for and how they are co-ordinating their work.

A number of important functions come under the re-sponsibility of the ministry (ministries), but thesemay often be carried out by subordinate agencies.Some countries have few, and some have many.The important consideration is whether the highestgovernmental authority (the ministry or ministries)has an overview of the activities and makes surethey are performed well.

Many countries have an authority responsible forcontrolling pollution and for inspecting and monito-ring the environment and the activities that have animpact on the environment. If the country has anagency like this, it is necessary to map out the roleit plays in the waste management system. If suchan agency does not exist, the SAI should identifywho is performing these functions. If these functi-ons are not taken care of, it may be the responsibi-lity of the SAI to inform the appropriate authorities.

Depending on the type of waste, the authorities thatadminister or regulate the waste may be at the regi-onal or provincial level or at the local or municipallevel. All actors should be mapped out, even thoughsome of these actors may not come within the coreof the SAI’s mandate to audit.

26 A thorough understanding of the waste handlers is obtained when looking closer at the waste stream, which will be suggested under step 3.


The most typical waste handlers should be identifiedwithout going into great detail. In a basic chart, theinclusion of waste generators, waste transportersand waste operators is sufficient.26 All of these ac-tors may be private or public.

Figure 5 is a graphical presentation of relevant ac-tors associated with waste management. It gives avisual depiction of the actors that should be takeninto account. In a factual chart, each actor’s functi-ons and responsibilities should be described, andfeedback obligations and the authority to issue in-structions should be indicated. The arrows withquestion marks illustrate links between actors thatthe auditor should look for. Examples of different pu-blic entities that may have authority over the waywaste handlers conduct their activities are shown inboxes. Waste handlers are indicated with circles. Inthis chart, the role of the SAI is not identified be-cause it varies greatly among different countries anddepends on the type of waste.

For a presentation of charts that illustrate the actualwaste management systems in China, Canada,Poland and Norway, see appendices 2–8.

4.3 Step 3 – Take account of the waste stream

When the actors and their responsibilities are map-ped out the problems related to poor managementshould be considered. General knowledge related totypical weaknesses in management systems can beapplied.

The waste stream, as presented in chapter 1.5, is agood starting point when searching for defects inthe waste management system to establish an au-dit. Using the different stages in the waste streamas a guide, make sure that you cover all of the im-portant factors. The waste policy and the manage-ment system should include all of the stages in thewaste stream. Some reflections on how govern-ments may exert influence at the different stagesare therefore presented.

Stage one in the waste stream is prevention, andthe motivation behind this stage is the sustainableuse of resources in general. We should use no moreof the natural resources than necessary, and themanufacture of products that do not have any useful

Figure 5. Waste management chart that includes the waste handlers

Waste producers

International agreements

Legislative body

Supreme Audit Institution

?

?

Waste transporters

Waste operators

? ?

?

?

?

?

?

?

Subordinate agencies/bodies

Ministry of EnvironmentMinistries of transport, health, agriculture, fisheries, construction etc

Other subordinate agencies/bodies

Regional level government Regional level government

Local governmentLocal government


purpose is generation of waste. An example is un-necessary packaging on products. The objective ofpreventing waste generation is often included in acountry’s national waste policy. This is a challengingobjective because most countries have a goal ofpromoting economic growth, and, so far, economicgrowth has involved an increasing amount of waste.

The second stage is the generation of waste. The go-vernment could influence the amount of waste genera-ted through economic incentives, where the efficientuse of resources and a limited generation of wasteare rewarded. The polluter-pays principle27 is such anincentive. The obligation on producers to substitutehazardous chemicals with less harmful ones whenpossible is another possible instrument. Unless theactivity that generates waste is a government-run en-terprise, the waste-generation process is an internalaffair. The authorities must then rely on inspectionsand internal control systems to ascertain compliance.

The third stage of the waste stream is Recycle,Reuse and Recovery. Some governments have theobjective of recycling, reusing and recovering asmuch of the waste as economically and environ-mentally feasible. To make this happen, severalmanagement moves are usually called for. The dif-ferent waste materials must be sorted and treatedseparately. This entails that either waste genera-tors must sort their waste themselves or theremust be a sorting procedure after waste collec-tion. To motivate the desired behaviour amongwaste generators, economic incentives could beused, such as refunds on returns or lower fees forsorted waste than for unsorted. Legislation mayalso enforce recycling, e.g. through an obligationon the seller of products to accept the return ofwaste.

The forth stage, the collection of waste, is usuallyregulated to some extent by local or national autho-

27 Principle 16 of the Rio Declaration: "the polluter should, in principle, bear the cost of pollution".

Accidents may occur when flammables are transported. Odd Steinar Tøllefsen/Scanpix


rities and may be handled by public or private ac-tors. Again, control is a key instrument.

The fifth stage is the transport and export ofwaste. There are usually official requirements forthis activity. The operators may be either public or private. The transport of hazardous chemicalsrequires firm regulations to avoid possible acci-dents. When it comes to the export of hazardouswaste, there are strict international rules to be fol-lowed.

The treatment and disposal of waste is most oftensubject to regulations from the authorities. In manycountries, an operating permit is required, and in-spections are common practice.

The possibility of illegal dumping, stage seven, mustbe acknowledged, and necessary measures must betaken to deal with this problem. There exist a num-ber of instruments that can be used to implementthese measures, such as monitoring and inspecti-

ons, but their use must be based on a solid statu-tory basis. Both the permission to conduct inspecti-ons and appropriate sanctions must be in place.

Waste that is not properly handled ends up in conta-minated sites. These may be the result of poor ma-nagement in bygone years, which needs to be ad-dressed today. The polluter-pays principle may beapplied, but with old damages it may no longer bepossible to hold the original polluter responsible.

From the auditing point of view, there are questionsthat the auditors can ask at each of these stages toassess the quality of the management system rela-ted to the waste stream.

In the following section, we will discuss at greaterlength a number of relevant audit questions that an auditor may raise to assess the quality of wastemanagement and problem areas that may be revea-led by audits. Each of the audit topics may be ad-dressed at each of the stages in the waste stream.

The poor subsist by searching for recoverable objects in a waste dump. David Trood / Samfoto


4.4 Step 4 – Consider audit topics – choose focus

Once the most serious risks are identified, the struc-ture of authority established and the challenges rela-ted to the waste stream revealed, a focus for the au-dit may become quite apparent. However, there are awide range of audit questions that may be asked andapproaches that may be chosen.

4.4.1 Consider audit topics

We have clustered key audit questions under hea-dings that capture different ways of evaluating themanagement system and have called them audit to-pics. Nine topics with related questions have beenidentified:

Topic 1 – Existence of waste policy

Is there a waste policy that applies to every stage ofthe waste stream? Is the waste policy at differentstages consistent with the general environmentalpolicy?

Topic 2 – Compliance with national environmental policy

Have the general environmental policy and thewaste policy been reflected, specified, and put inconcrete terms in instruments such as legislation,plans, budgets and financial tools? Are there anygaps or inconsistencies in the waste legislation?

Topic 3 – Risk management

Are the risks posed by waste for the environmentand health being sufficiently managed? Does the go-vernment have an overview of these risks and aremeasures being taken to manage them? For in-stance, are there reporting systems for incidentsfrom the operating to the executive level?

Topic 4 – Quality of the implementation process

Have policies and regulations been implemented efficiently and effectively? Have there been delays in the implementation and have the resources beenwell-spent? Did the government conduct sufficientimpact assessments or other prior investigationsbefore implementing a new waste initiative?

Street litter in developed country. Jamie Parslow / Samfoto


Topic 5 – Performance of the waste management system

Is the structure of the waste management systemappropriate for solving the challenges that wasteentails? Is there a distribution of responsibility,and, if so, does this influence accountability? Dothe responsible agencies have the necessary in-struments for fulfilling their obligations regardingwaste management? Do the chosen instrumentssuch as legislation, plans, budgets and financial tools ensure the achievement of the policy objecti-ves? Does the system achieve the optimum output– in terms of quantity and quality – from the inputsand actions?28

Topic 6 – Compliance with national law and regulations

Do the actions of the government departments, mi-nistries and other relevant agencies comply with therelevant rules and regulations, specifically financial

requirements? Are all waste activities and liabilitiesaccurately accounted for? Are there any illegal practi-ces in connection with the waste handling?

Topic 7 – Compliance with international obligations

Do the policies, legislation and practices relating towaste management comply with the internationalobligations and commitments to which the countryhas agreed?

Topic 8 – Monitoring

Are there adequate systems for monitoring the wastehandling? Is there a system that ensures a neces-sary overview of the waste handling? Is relevant in-formation gathered, e.g. through reporting systemsor registers, and is that information of good quality?Are there control and inspection procedures in placeto ensure compliance with requirements, and dothese work well? Have necessary sanctions been es-tablished, and are they adequately used?

28 Implementation Guidelines for Performance Auditing Standards Exposure draft, page 10

Street turned into dump in developing country. David Trood / Samfoto

Topic 9 – Effects of other government activities

Is the waste from other government environmentalor non-environmental activities or programmes pro-perly managed? Do the public ministries, depart-ments and agencies manage the waste created byactivities under their authority?

4.4.2 Choose a focus

The inclusion of these audit topics in the process ofchoosing a focus for an audit gives the following threedimensions: type of waste, stage in the waste streamand audit topic. These are visualized in figure 6.

The figure gives the auditors an overview of themost pressing areas to look at and of possible

approaches. Examples of questions derived fromthese three dimensions are:

• Is there a policy in our country for the preventionof hazardous waste?

• Does the legislation relating to the treatment of solid waste comply with the environmental policy?

• Is there adequate monitoring of the disposal ofradioactive waste?

In actual audits, usually more than one of thesequestions is addressed, as is the case in most ofthe audits that will be presented.


Figure 6. Graphic depiction of the three dimensions behind an audit focus

Waste

Solid Waste

Hazardous Waste

RadioactiveWaste

Prevention

Generation

Recycle Reuse Recover

Collection

Transport Export

Illegal dumping

Treatment Disposal

Contaminated sites

Other government activities

Risk management

Implementation of systems

Performance of systems

Compliance with national law

Compliance withinternational law

Monitoring

Existence of policy

Compliance with policy


5 Audits of Waste Management

To facilitate the planning of your waste managementaudit, it may be useful to see how other SAIs haveapproached the field, so as to profit from what theyhave learned. We will therefore present a set ofexamples of audits that reveal the most pressingproblems related to waste management that haveconfronted a number of SAIs. The examples aregrouped under the nine previously presented audittopics. The emphasis in the audits as they are pre-sented here is on the findings.

A significant number of audits have been conductedin the last decade. During the years 1997–99, INTO-SAI members produced a total of 103 audit reportson waste in 49 different countries. As many as 20%of the SAIs stated that they were planning audits onwaste in the next three years29.

When reading the audit examples, there are severalaspects it is important to be aware of. First, someof the examples are quite old and may no longergive a true picture of the situation today. Secondly,the examples do not present a full description of theaudit. In some cases, certain parts of an audit havebeen emphasised or selected to illustrate a particu-lar audit topic. The focus is on deviation, and manyfindings related to good practices have been leftout. However, the examples here were selected be-cause they are assumed to be relevant and informa-tive for other SAIs.30

The topics constitute typical problem areas that au-dits reveal. Under each topic general considerationswhen using the approach will be presented. Some ofthe examples may address more than one of the to-pics, but are only presented under one topic.

5.1 Topic 1 – Existence of waste policyIt can be argued that the existence of a nationalwaste policy is a prerequisite to any SAI´s examina-tion of waste management, and that without such a

policy the SAI lacks a foundation for an audit. At thesame time, the existence of a national waste policyis also an issue that a SAI may raise.

Some international conventions oblige national go-vernments to take measures, that may necessitatethe formulation of some sort of national policy. Theexistence of a waste policy may therefore be audited using an international convention or agree-ment to derive audit criteria.

Both the waste stream and the types of waste mayprovide good starting points for investigating the existence of a waste policy in a country. Such an audit might reveal an absence of or gaps in thewaste policy for one or more of the stages in thewaste stream or for one of the types of waste.

It is also important to expose inconsistencies bet-ween the waste policy at the different stages in thewaste stream and the general environmental policy.

No examples of audits that set out to analyse theexistence of a waste policy or the consistency bet-ween general environmental policy and waste policyhave been found.

5.2 Topic 2 – Compliance with nationalenvironmental policyThe parliament or equivalent legislative body deci-des on a policy, which the executive body is thenobliged to specify so as to make the aims of thepolicy more comprehensible, distinct and operatio-nal, often by means of legislation. Fulfilling this obligation is a focal issue for many countries’SAIs.

According to the Rio Declaration, Principle 11, firstsentence, states have an obligation to provide thislegislation: "States shall enact effective environ-mental legislation". Although the Rio Declaration is

29 Information gathered in the third questionnaire conducted by the INTOSAI Working Group on Environmental Auditing in 2000. More information availableat http://www.environmental-auditing.org/

30 Many of the examples presented in the report have been rephrased and edited.When referring to a Supreme Audit Institution in this document, it will be referred to as the SAI of X or the X’ian SAI instead of using the official name of the institution. This has been done to make the text more easily readable.


not legally binding, it offers guidelines and mayserve as an audit criterion on the basis of which theSAI can call attention to the absence of legislation.

The evaluation of compliance also implies the analy-sis of consistency among the different laws and re-gulations. For instance, there may be legislation un-der other ministries that does not incorporate the re-quirements and goals of the waste policy andlegislation.

A question that it may be relevant to ask is whetherthe country’s environmental, health and safety legis-lation lay down requirements for basic systems forsolid waste, hazardous waste and radioactivewaste. The absence of such legislation may need tobe reported.

The obligation to specify the policy also has implica-tions for the regional and local levels of governmentor authority. These bodies should make sure thatthe substance of the regulations and actions com-plies with the intentions of the policy.

Sometimes the political decisions that are madecannot realistically be implemented in the immedi-ate future, for instance because the required fun-ding is not provided. The policy might be intended tofunction as a vision. In this case, a strict focus ondeviation and unsuccessful practices might subjectthe countries that have ambiguous goals to theharshest criticism.

Two of the examples below reveal challenges whentrying to implement ambitious waste policies. A thirdexample criticizes the government for not settingambitious goals. Several of the examples under ot-her topics have lack of regulation as one of severalfindings, but they do not refer explicitly to the lack ofcompliance with policy.

In an Estonian audit from 2001, the focus was onthe prerequisites for implementing the nation’swaste policy.In other words: to what extent are the necessaryconditions for the successful implementation of

Mikkel Ø

stergaard / Samfoto


the waste policy in place? The Estonian waste policy sets the following goals:

– To prevent waste generation– To reduce the amount and harmfulness of

generated waste– To broaden the scope of recovery operations

(reusing, recycling, composting and incineration)– To process and neutralise waste in accordance

with the relevant standards– To deposit waste and dispose of it in an

environmentally sound manner

The Estonian SAI has concluded that the national,county and local authorities have not establishedadequate prerequisites for the successful imple-mentation of the waste policy. Shortcomings arerelated to:

Information/monitoring: the management and ac-counting of and statistical information about wastemanagement is insufficient and unreliable. Thereis no precise information about the generation,shipment, recovery or treatment of waste, and theaccuracy of the information provided has not beenverified.

Strategic framework: there is no national wastemanagement plan to serve as the foundation forthe planning of waste management, the refine-ment of development plans, the decisions to esta-blish waste disposal sites and the determinationof financing needs. The lack of such a plan hascomplicated the planning of waste management bylocal governments and developers of waste dispo-sal sites and waste treatment facilities.

Financing: under the current financing, the goalsfor non-hazardous waste disposal will take ten times longer to achieve than the implementationcapacity allows.

Management: the management of the waste policylacks unity and co-ordination. The necessary orga-nisational prerequisites were not established in atimely manner.

The report is available in English at http://www.riigikontroll.ee/

The SAI of the Netherlands published an audit in 1997 focusing on waste prevention. The SAI investigated the extent to which the objec-tives of the country’s waste prevention policy weremet and examined the development, deployment

and broader impact of the policy instruments thatwere employed.

Since 1979, prevention has been given top priorityin waste policy, ahead of recycling, incinerationand landfills. Furthermore, it is only in this area ofwaste policy that the central government, ratherthan the provincial authorities, bears primary re-sponsibility for formulating and implementing thepolicy. The Consultative Body on Waste co-ordina-tes the efforts of the central government and theprovincial and local authorities.

Achievement of objectives:The SAI concluded that the Ministry was not suffi-ciently informed as to whether the overall preven-tion target and the targets for the priority substan-ces that it investigated were being achieved.

Policy instruments:The SAI concluded that there had been a shift ofemphasis in the development and use of these in-struments. The emphasis had shifted from an ap-proach that focused on individual priority wastesubstances to a more generic approach that targe-ted the entire waste stream. The generic approachwas also an integrated approach because thewaste-prevention policy was harmonised with otheraspects of the nation’s environmental policy.

Prevention policy for priority waste became a per-manent feature of target-group talks with industry.These talks between the government and differentsectors of industry were designed to produce agree-ments at the sector level on each sector’s contri-bution to achieving environmental policy objectives(including agreements on waste prevention) andon compliance with the agreements.

Some preparations have also been made for usingthe expanded powers available under theEnvironmental Management Act to foster wasteprevention through licensing and general rules (re-gulatory instruments). However, little use has actu-ally been made of these instruments.

The SAI was of the opinion that the Ministry’s fore-casts concerning the impact of waste disposal ca-pacity and cost on waste prevention were inade-quately substantiated.

The SAI also gave a closer look to the broader im-pact of waste prevention policy on corporate envi-ronmental plans and licences in the chemical in-dustry. It concluded that the corporate environmen-tal plans had been drawn up according to agreed


procedure. However, there is still room for impro-vement with regard to the status of waste preven-tion in these plans and in licences. In particular,the competent authorities could pay more atten-tion to the substance of the waste prevention mea-sures included in the plans, to their formalisationin licences and to companies that have a passiveattitude to waste prevention.

Despite the above reservations, the SAI approvedof the stimulatory and regulatory instruments deve-loped to promote waste prevention in companies.However, it commented that there had been toolittle use of these instruments and that they havetherefore failed to have a broader impact. The vastmajority of companies had not yet undertaken anywaste prevention efforts.

The SAI of Costa Rica audited the solid wastemanagement in two municipalities in 2000.One of the most significant issues associated withenvironmental damages in Costa Rica’s municipali-ties is the disposal of solid waste. This problem ischaracterised by inadequate management by thepublic institutions that have provided the service inrecent decades and by the public offices responsi-ble for the environmental monitoring.

The main objective of this audit was the evaluationof the plans and programmes developed by twomunicipalities in the metropolitan area. Also evalu-ated were the management and inspections con-ducted by the Ministry of Health (MINSA), and theMinistry of Environment and Energy (MINAE), whichare in charge of these inspections.

As a result of this study, the SAI has found thatthe use and management of solid waste is not anintegrated process with structural plans and pro-grammes to prevent their negative impact on theenvironment and human health. The initiatives ta-ken by the institutions have often been isolatedand repetitive.

Another finding of this study is that the actions bythe institutions mentioned do not heighten peo-ple’s awareness and do not help encourage goodhabits with regard to the classification and appro-priate disposal of waste. There are no public pro-grammes that provide opportunities to separatewaste or recycle or reuse materials.

The massive accumulation of solid waste at thetwo studied municipalities is a major contradictiongiven the available modern technologies used in

other places to separate the solid waste for possi-ble reuse. On a short-term basis, these two evalu-ated municipalities are unwilling to introduce strategies for the proper classification and trans-portation of waste. They thereby limited their pos-sibilities of managing the waste.

The financial support is also unsatisfactory. Thebudget does not allocate enough resources to co-ver the costs related to the collection and final dis-posal of the waste. Furthermore, the planning andtechnical strategies for achieving these objectiveswere both inadequate. As a result of these short-comings, more than 145,000 tonnes of solidwaste per year are not under proper managementto prevent environmental damage or negative im-pacts on human health.

The inspections conducted by the public instituti-ons (MINAE and MINSA) do not help overcome thisproblem, because these actions do not promotebetter public services according to the environmen-tal standards that protect ecosystems. These twoministries have concentrated their efforts on finaldisposal, but this approach is partial and does notreduce the high volume of waste treated withoutseparation. Thus, the cities are subjected to nega-tive impacts, such as water pollution, foul odoursand hazardous gasses.

5.3 Topic 3 – Risk managementThe environmental and health risks posed by wastemay be used as a point of departure for an audit.Possible questions that may arise are whether thegovernment has an overview of the risks at eachstage in the waste stream and whether measuresare being taken to manage these risks.

In general, risk can be defined as the probability andconsequences of an unwanted incident. In keepingwith this definition, government efforts at risk mana-gement can be of two different kinds. First, the go-vernment can take steps to reduce the probabilitythat waste will have a negative impact on the envi-ronment. Secondly, risk management involves fin-ding ways to limit the negative consequences onceit is clear that waste does have an unwanted impacton the environment or public health.

It is also possible to draw a distinction between therisk of negative incidents, and long-term risk. Forexample, a measure for reducing the probability ofan unwanted waste-related incident may be to en-sure the safe transport of toxic waste. Then, if a ne-gative transport-related incident actually occurs the


government should be ready to handle the situation.This latter point is strongly associated with prepa-redness.

With regard to long-term risk, one important questionis whether employees that handle waste are informedof the risks inherent in their work, both to themselvesand to the environment. Proper information may reduce both the probability that waste will become a problem, and any consequences that may occur.More concretely, if waste is handled in a proper man-ner, the probability of negative impacts is reduced.

There should be systems to ensure that informationabout risks at lower levels reach the authority thathas the power to improve these conditions.

Several of the audits include the risk associated witha waste management area. Many have mapped outthe environmental impacts as a point of departure.

The Japanese SAI conducted an audit in 1996 onthe Nuclear Waste Storage Budget Request andExecution. The focus was on "the Corporation",which runs a centre that performs research and de-velopment on the processing and disposal of nu-clear waste, among other activities. The centre sto-res solid radioactive waste in two open-air under-ground radioactive waste pits built between 1967and 1972 and in radioactive waste depots. In theopen-air pits, the radioactive waste is stored in pitdrums. Laws and regulations relevant to nuclear fuel and nuclear reactors stipulate tight control onradioactive waste storage to safeguard the outside environment from damage caused by waste leakage.

The Japanese SAI became aware of the fact thatthe Corporation’s radioactive waste storage hadbeen deficient for a long time, which resulted in pitdrum corrosion. Despite this corrosion, theCorporation had diverted its pit-repair budget to other purposes. In light of the high public concernabout this problem, the SAI examined theCorporation’s budget requests, execution, etc. TheSAI’s study showed that despite its deficient radio-active waste storage facilities, the Corporationused its facility repair budget to carry out only mini-mal temporary repairs and diverted most of the re-pair budget to other purposes. The SAI concludedthat the budget requests and implementation overa number of fiscal years largely failed to addressthe actual situation and also failed to properlysafeguard the radioactive waste stored in the pits.In light of the growing public concern about safetyand security at the nuclear facilities, it is essential

that the Corporation ensures proper budget re-quests and implementation, and thereby ensuresproper nuclear waste control.

In 1995, the SAI of Israel audited the handling of the disposal of hazardous waste. The audit focused primarily on the Ministry ofEnvironment’s preparations for handling all of thehazardous waste produced in Israel and on the en-forcement of the regulations relating to its dispo-sal. The activities of the hazardous waste disposalcompany that operates the central waste site werealso examined.

Some of the findings were:Until the establishment of the Ministry ofEnvironment in 1988, the handling of hazardouswaste was assigned to a large number of officialbodies, which were not sufficiently co-ordinated toenforce compliance with the directives relating tothe treatment and disposal of the waste and to pu-blish the relevant professional instructions.

With regard to hazardous waste produced in largefactories, the Ministry had not completed its arran-gements for the treatment of the thousands of ton-nes of hazardous waste that had accumulatedover the years within the confines of these facto-ries. In addition, not all of the waste was treatedand disposed of according to the Ministry’s profes-sional directives, as required by law.

The Ministry only had partial information about theamount of hazardous waste produced in Israel andthe manner in which it was handled. To operate inan optimal manner, it was necessary to set up adata bank to record all the quantities of hazardouswaste produced and the manner of their disposal.The Ministry began to locate and centralise infor-mation, but did not complete this information sys-tem. The system was unable to provide a basis fora comprehensive system of routine monitoring andsupervision and of total enforcement of the law.

One of the findings was related to the absence ofregulations. Medical institutions and research in-stitutions annually produce thousands of tonnes ofinfectious medical waste that could endanger theenvironment and cause immediate harm to publichealth. The ways of collecting this waste for treat-ment and disposal had not been regulated by sta-tute, and, in practice, it was not properly handled.Some of this waste found its way to solid wastedisposal sites without proper treatment, and somealso ended up in unregulated sites.


The SAI of Israel concluded that the uncontrolledand unprofessional disposal of hazardous waste isliable to cause damage to the environment and toendanger public health. Therefore, it is necessaryto take immediate measures to prevent further ac-cumulation of untreated hazardous waste.

The SAI of Bolivia conducted in 1999 an audit ofthe environmental state of the water and soil atone pit of the sanitary filling. This included ananalysis of the environmental impacts and potenti-als, and an evaluation of the environmental perfor-mance of the entities involved in managing andcontrolling this pit.

The main findings were:The sanitary burying carried out from 1996 to2000 entailed changes in the environmental stateof the water and soil. Different analyses (physical,chemical, bacteriological) of the soil and subterra-nean water showed the presence of contaminantsfrom the pit, and the current calculations were performed to estimate potential environmental damage.

The audit showed that the pollution of the soilaround the pit and the subterranean water directlyassociated with the pit was caused by the repea-ted non-compliance with regulations and systema-tic failures in performance on the part of the firmin charge of the sanitary filling. Partial failures onthe part of the municipal office in charge of inspec-ting the sanitary burying operations also contribu-ted to the negative environmental impacts.

The audit found deficiencies related to the monito-ring of watercourses, the covering of waste, thecontrol and treatment of percolating liquids, andthe diversion of rainwater and exterior canals. Thefirm was held responsible for not fulfilling the con-tract, but the municipal office shared the responsi-bility for the potential environmental damage, as ithad not requested strict compliance with the obli-gations from the contracted private operator.

The audit also found that the local government hadnot implemented the regulations related to the treatment of hazardous waste from hospitals inthe pit.

The SAI of Colombia conducted in 2000 an audit of the operation and management of theCurva de Rodas landfill. One of the focuses wason whether the authorities had applied the provisi-

ons of the environmental legislation that addres-sed the risk of serious damage to the environ-ment.

The Curva de Rodas landfill was designed for thedeposit of solid waste. The site commenced opera-tion in November 1984. The landfill was due tocomplete its working life in 1996, but the localauthority decided to extend activities until 2005.Between 1995 and 1999, there was no party re-sponsible for the operation of the landfill otherthan a local authority. There are no documents orwritten records of operations from this period,which means that it was impossible to give a pre-cise account of the current condition and stabilityof the landfill.

The main environmental problems discovered atthe landfill site in 2000 are related to the dumpingof untreated waste into the Medellín river andRodas stream:

• the inadequate disposal of hospital and hazar-dous waste

• the inappropriate management of rainwater

• the alteration of the Rodas streambed by the con-struction of a 1,049–metre-long superstructure

• the burning of vegetable matter

• offensive odours

• the presence of poultry droppings and the uncer-tainty of their stability

This has led to opposition, concern and fear in the local community.

Faced with the risk of landslides and other poten-tial disasters caused by the continuing deposit oftonnes of waste, the regional authority insistedthat the operators of the landfill draw up a plan forclosing the landfill by the year 2001.

The Colombian SAI reported that the regional authority, which has the legal authority to enforcecompliance with environmental regulations and todraw up plans to diminish the damage to the envi-ronment from various projects, has not been effec-tive in its management. The regional authority cont-inued to delay procedures and had not overseenthe comprehensive and appropriate application ofthe existing legal provisions relating to the opera-tion of the landfill.

Furthermore, the SAI concluded that the environ-mental authority responsible for overseeing theoperation of the landfill site should apply the provi-sions of the Political Constitution that refer to themonitoring and prevention of cases of degradationof the environment. The authority should also apply


the provisions, which state that if there is a risk ofserious and irreversible damage, the lack of abso-lute scientific proof shall not be used as a reasonto delay the adoption of effective measures to ad-dress the degradation.

The Colombian SAI concluded that the decision toprolong the working life of the landfill was not justi-fied. Taking into account the precautionary princi-ple, the absence of scientific proof of the seriousdamage or danger that prolonging the working lifeof the landfill may entail for the environment andcommunity cannot be construed as an obstacle totaking pertinent action and measures to avoid thisdamage. The damage would result in higher envi-ronmental costs as a consequence of inadequateoperation and management of the landfill site.

5.4 Topic 4 – Quality of the implementation process This topic covers the initial phase of a waste mana-gement initiative. Time and resources should bewell spent and the goals that underlie the initiativeor action should be accomplished. A good selectionof instruments is also important.

One obvious goal for a waste management initiativeis the implementation of existing legislation. Thus,the construction of a new waste dump that does notcomply with the appropriate legislation can be regar-ded as inadequate in the implementation process.

Before the establishment of a waste disposal acti-vity that may have a negative impact on the environ-ment, an impact assessment should be conducted.

Principle 17 of the Rio Declaration states: "Environmental impact assessment, as a nationalinstrument, shall be undertaken for proposed activi-ties that are likely to have a significant adverse im-pact on the environment and are subject to a deci-sion of a competent national authority."

Assessing the impact on the environment before in-tervening is easy to acknowledge as an ideal. It isalso in keeping with the precautionary approach.The following examples from Israel and Paraguay fo-cused on the lack of prior assessment of the envi-ronmental impact of waste disposal activities.

The SAI of Paraguay conducted an audit of theCateura dump in Asunción, the capital ofParaguay. This dump was established in 1985,and the audit was conducted in 1997–98.

The SAI focused on the environmental administra-tion by the municipality of Asunción, the public aut-hority responsible for the dump, and on the moni-toring by the governmental supervision agency, SENASA.

The management and control of the dump was in-vestigated with regard to national health legisla-tion and a resolution concerning the technical re-gulation of the management of solid waste. In ac-cordance with these regulations, all localauthorities are supposed to compile a ten-yearplan for urban cleanliness. The municipality ofAsunción did not have an urban cleanliness plan,and SENASA had not requested such a plan fromthe municipal authorities. The investigation conclu-ded that SENASA had neglected its duty as a su-pervision agency for solid waste for a period of 12years in the case of Cateura.

The investigation found that when the dump wasbeing established, a large number of problem is-sues had not been dealt with, resulting in the follo-wing serious violations of the legislation:

– The spread of insects causing the transmissionof disease to humans and animals

– Leaching of contaminated water with a highcontent of organic substances

– Foul odours– Risk of explosions and fires due to gases

generated by the decomposition of waste– Waste was stored in areas subject to flooding,

where floodwaters can carry waste away– Sewage was unloaded in an uncontrolled way in

a lake inside the dump– Disposal of hospital waste that might lead to

severe environmental contamination

National legislation also prohibits settlements inthe dump area, but the SAI found humans living inthe Cateura dump.

According to the master plan for management of so-lid waste, the Cateura dump was to be closed in1999. However, this was delayed, and instead themunicipal authorities of Asunción developed a pro-ject for the rehabilitation and expansion of theCateura dump. This project should have been appro-ved by SENASA, but this was not the case. A studyof environmental impacts is also required for thistype of project, but it was uncompleted. There wereno plans for closing the dump, but there were plansfor developing the urban environment and creatingan ecological park in the Cateura area, both of whichdepended upon the closing of the dump.


In 2000, the SAI of Paraguay did a follow-up inve-stigation of the Cateura dump. The local authori-ties were then following a schedule provided bySENASA. The SAI now found that the sewers ope-ned directly into Lake Cateura, new areas of thedump were being planned in areas affected byflooding, and the authorities still had no controlover humans and animals entering and leavingthe dump. The SAI observed human settlementswith electricity and running water inside thedump, and the representative from Asunción municipality informed them that about 1000 per-sons worked of the dump. Furthermore, the localrepresentative pointed out that the closing of theCateura dump depended on the process of buy-ing a new piece of land for a new intermunicipaldump. The SAI of Paraguay recommends that thelocal authorities speed up this process in accor-dance with the master plan for the managementof solid waste.

in 1991 the SAI of Israel conducted an audit ofthe disposal of solid waste. One of its main objec-tives was to evaluate the implementation of theNational Outline Plan for solid waste disposal.

Among the findings was the revelation that the de-tailed planning of the disposal and treatment ofsolid waste had not been completed for all partsof the country. There was a failure to implementthe directives issued by the National Planning andBuilding Council to the district councils to includedetailed plans for waste-disposal sites from theNational Outline Plan for Waste Management inthe district outline plans. There was also a failureto close active dumps that should have been clo-sed. As a result, only one-third of the solid wasteproduced by the country’s population was adequa-tely disposed of.

Furthermore, the waste was removed to manywaste disposal sites that were not operated in ac-cordance with proper sanitation requirements, cau-sing damage to surface and groundwater reser-voirs. Officials did not ensure compliance with le-gislation and did not exercise their authority.

There was a failure to plan and implement exten-sive recycling of solid waste, although several com-mittees of experts recommended recycling andpointed out that it was economically and environ-mentally beneficial. No comprehensive and updatedstudy was undertaken to determine the feasibilityof burning solid waste to produce energy. Therewas no analysis of the possibility of combining the

three methods for disposing of solid waste – burialat waste disposal sites, recycling, and incineration– and of using them in regional and inter-regionalwaste disposal sites, where this would be possiblefrom an engineering perspective and where it wouldbe economically feasible.

5.5 Topic 5 – Performance of the systemIt is the responsibility of a country’s SAI to audit thewaste management system and determine how wellthe system is performing. There are a large numberof issues that naturally arise here, as to whether thesystem meets the challenges that waste entails. One important task is to map out the relevant actorsand their responsibilities to determine whether all ofthe necessary functions are managed and the linesof responsibility are clear.

For example, there may be a ministry of environmentthat has the overall responsibility to ensure compli-ance regarding waste. If such a ministry does notexist, it may be necessary to map out the partial re-sponsibility held by different government bodies. Ifthere is more than one body in the central adminis-tration that has some kind of responsibility, a natu-ral audit question is whether this entails any risk.Concretely, does the scattering of responsibility frag-ment accountability? This question was raised bythe Canadian SAI in an audit presented below, whichfocuses on the management of radioactive waste.This audit also specifies the criteria that must be ful-filled in order to have sound management.

A focus on the performance of the system also im-plies the scrutiny of whether the responsible agen-cies possess the necessary instruments for meetingtheir obligations and whether these are the most ef-fective and efficient means of so doing.

Within waste management there may be program-mes or actions that are one of a kind. Although theaudit of such activities may have no impact on fu-ture practices, it is nevertheless important to consi-der them as well.

Several SAIs have performed full-scale audits oftheir waste management systems, and the auditsare presented in the following pages.

The SAI of Brazil conducted an audit of the radio-active waste management programme, publishedin 1999. As the result of an accident31, theNational Commission of Nuclear Energy (CNEN)


initiated efforts to improve control mechanisms to prevent similar occurrences. The objective ofthe audit was to identify weak points in the pro-gramme for refuse/waste control and to considerprocedures that could contribute to improvementsin performance.

The audit was justified by the potential risk of envi-ronmental damage from activities involving radio-isotopes. The biggest benefit of any improvementin the programme for radioactive waste manage-ment is the reduction of the risk of occurrence ofradioactive accidents.

The following audit questions were formulated:

• Is the register of radioactive installationscomplete, is it regularly updated, and is itused in the waste management programme?

• Does CNEN oversee the waste managementas envisaged in the radiation-protection plan?

• Do the agencies linked to the sanitary surveillance offices and the environmental supervision agencies participate or will theyparticipate in the control and supervision ofwaste management? Is there any overlappingand linking of the tasks executed by these entities and CNEN?

• Does CNEN plan and execute the collectionof the radioactive waste in a timely and efficient way?

• Is the short-term storage of radioactive wastecarried out efficiently?

• What is the service rendered by CNEN to its clients like?

• Has the Research Programme on Waste Management achieved the expected results?

The main findings were:Evidence was found that the register of users ofradioactive materials kept by CNEN is not com-plete and is outdated.

CNEN is unable to fully comply with the plan forthe annual inspection of radioactive installations,mainly due to budgetary and financial restrictionsthat affect the availability of resources for coveringexpenditures related to the airfares and per diemof the inspectors.

There is not enough co-ordination of action be-tween CNEN and the sanitary surveillance offices.This undermines the effectiveness of the control ofradioactive materials in the country because CNEN

does not have the authority to apprehend material,to shut down installations or to fine their owners.Furthermore, from the operational point of view, ithas limitations as a result of its centralised struc-ture and lack of resources. Likewise, the sanitarysurveillance offices do not have the technical exper-tise to act on their own in place of CNEN.

It was found that the CNEN refuse depots are al-most full and that CNEN is not monitoring the in-creases in the amount of waste in the depositsand has no routine forecast of the amount ofwaste that will be deposited annually in each ofthem. There is a considerable risk that the depo-sits will reach critical levels and that theCommission will not have any safe options for de-positing waste that is produced continuously.

One of the findings was related to weaknesses inthe legislation. According to Brazilian law, the use,storage or maintenance of sources of radioactivityin contravention of security rules is criminal.Radioisotopes are one example of such a source.However, there is no clear legislation compellingthe users of radioisotopes to deliver the sourcesof radioactivity to the National Commission ofNuclear Energy and to cover the costs of that deli-very. The Commission even disagrees internallyover this matter. Therefore, there is no guaranteethat the users will deliver the sources of radioacti-vity when they are no longer in use.

The Canadian SAI conducted an audit in 1995 ofthe federal management of radioactive waste. The following general audit criteria were used:– Roles and responsibilities for dealing with

radioactive waste in Canada should be clearlyassigned.

– The federal government should identify theproblems of managing spent fuel, low-levelradioactive waste (LLW) and uranium tailings in Canada, develop a strategy for their manage-ment and ensure that plans and budgets are in place to address their management, includingtheir disposal.

– Appropriate and timely action should be initia-ted by the federal government to deal with all classes of radioactive waste in Canada.

– Federal initiatives dealing with radioactivewaste in Canada should be cost-effective andshould include reporting to Parliament on thecosts and results of these initiatives.

31 The accident occurred in Goiânia. Two scavengers found and opened a caesium canister in an abandoned clinic, provoking a major nuclear disaster.Four people died and more than seven hundred people were contaminated.


– The government should protect the federaltaxpayer from potential liabilities as a result of radioactive waste.

– Any issues that remain unresolved in findinga long-term solution to radioactive wasteshould be disclosed to Parliament.

With regard to High-Level Radioactive Waste(HLW), the Canadian SAI concluded that this wasteis safely stored at reactor sites. However,Canada’s inventory of HLW continues to grow. It isanticipated that active reactors will produce a totalof over four million bundles of spent fuel by theend of 2033. This volume would be equivalent insize to about seven Olympic-size swimming pools.Although the current wet and dry storage are ac-ceptable interim methods for storing HLW, it is re-cognized by the Canadian government, operators,experts in the field and regulators in other coun-tries that a long-term solution is necessary. Such asolution is necessary because some of the radio-active material in spent fuel remains hazardous fortens of thousands of years.

The Canadian SAI believes that it is important tohave some form of benchmark with which to as-sess the progress of the Canadian HLW program.At the recommendation of experts in the nuclearindustry, they visited Sweden, Finland and Franceto discuss their radioactive waste managementprogrammes. In the opinion of the experts, thesecountries had made progress in finding solutionsfor their highlevel as well as their low-level radio-active waste.

Federal responsibility for managing Canada's radio-active waste, including the search for long-term so-lutions, is divided among many players. With theexception of the assignment of residual responsi-bilities for uranium tailings, current federal respon-sibilities for radioactive waste regulation, storageand research are clearly defined and assigned.However, roles and responsibilities for implemen-ting long-term solutions for high-level and low-levelwaste are not clearly defined and assigned.

While the various federal players understand theirresponsibilities, they are not always collaboratingwith other non-federal players on a common visionand agenda for disposing of Canada's radioactivewaste. The federal government, in consultationwith major stakeholders, needs to develop thiscommon vision and agenda.

The various efforts of the many federal players in-volved have not yet resulted in a timely resolution

of the difficult national problem of disposing of theHLW and LLW. Today, Canada has no disposal fa-cilities for any of its high-level or low-level radioac-tive waste. Canada has not kept pace with someother countries in moving toward the implementa-tion of a long-term solution for HLW or in develo-ping operational LLW disposal facilities.

This audit is available in English athttp://www.oag-bvg.gc.ca/

The SAI of China audited in 2002 theManagement of Medical Waste. After sampling,the SAI audited four hospitals and one medicalwaste incineration site in a selected city to obtaingeneral information on medical waste manage-ment and disposal in that city and to propose sug-gestions for improvement.

Audit findings:– The capacity of medical waste collection and

disposal is quite inadequate.– No strict internal medical waste control system

was set up in hospitals. The hospital cannot determine the amount of medical waste produ-ced, nor can it control the flow of that waste.

– The management of medical waste is slack. For example, in some hospitals, warning signs for dangerous waste were not printed on trash bags, transport vehicles or storage sites; medical waste was not sterilized before being canned; some medical trash bags were not leak-proof; many storage sites and transportvehicles were inadequately equipped with no refrigeration or leak-proofing facilities.

– Most medical waste incinerators were out-of-date with no mechanical refuse feeding or dust--catching devices. Smoke, dust and residues deriving from incineration exceeded the permit-ted level, and the residues of mud after waste-water processing did not reach the reprocessingsites specified by the environmental protectionauthorities, and thereby contributed to repol-lution.

Main causes of these problems:– Inadequate investment in the infrastructure for

the collective processing of medical waste, and no large-scale collective disposal capacity for solid waste has been built

– Lack of public awareness of the harm caused by medical waste and limited knowledge of pollution prevention

– Defective internal control of medical waste in hospitals


The SAI of Mauritius audited in 1998 the govern-ment’s solid waste management. Mauritius gene-rates some 380,000 tonnes of waste per annum.This represents a waste volume of approx. 1.9 mil-lion m3, which is equivalent to covering the surfacearea of a football pitch (5000m2) with waste up toa height of 300 metres.

The total cost borne by the government relating tothe collection and disposal of waste has increasedsignificantly over the years. Although consultantswere in favour of a cost-recovery system, the govern-ment has not yet reached a decision on this issue.

The strategic plan was prepared more than tenyears ago, but there has been a delay in the imple-mentation of the plan.

Control and monitoring were inadequate. TheEnforcement Unit of the Ministry issued paymentson the basis of only one or two visits to the con-tractual sites per month. It is therefore uncertainwhether adequate services were provided for themoney that was spent. Local Authorities have sta-ted that they were not able to ensure effective con-trol and enforcement of the scavenging resultingfrom a lack of personnel.

Waste storage was inadequate. Some 160,000 to180,000 households, i.e. 55 to 62% of the totalnumber of households in Mauritius, had no stan-dardised storage receptacle for household waste,even though consultants had been recommendingthe use of such receptacles since 1994.

The waste collection service was inefficient. Eachyear 39,600 tonnes of municipal waste, i.e. 15%of the total waste generated in Mauritius, is notcollected. According to the Household Census2001, some 32,480 households have no collec-tion service or only an irregular service. These hou-seholds must therefore make use of other met-hods of refuse disposal, such as dumping.

Uncontrolled and illegal dumping is therefore a se-rious problem in Mauritius. In addition to municipalwaste, 7,800 tonnes of construction and demoli-tion waste are disposed of in an uncontrolled andillegal manner each year.

There is no sorting of waste, and no recycling orcomposting facilities are available to minimise thequantity of waste for disposal. It was reported thata market study of composting showed that themarket for recycling is very small, which meansthat sorting would not be cost effective.

The SAI draws the following overall conclusion:Over the past ten years, the government has donemuch to improve waste management, but muchmore still remains to be done, especially in termsof waste collection and disposal. The implementa-tion of the strategic plan must not be delayed anyfurther so that the strategic goals can be attained.The government needs to know the total cost ofsolid waste management, and this can serve as aperformance indicator to aid planning, monitoringand decision-making.

The SAI of Italy reported in 2000 on the manage-ment of the extraordinary efforts to dispose ofwaste matter in Campania.Seven years ago, the situation with regard to wastein Campania warranted a declaration of a state ofemergency, and as a result, a special commissionwas established to manage the problem.

The management goals consisted of interventionsthought to be necessary to cope with the emer-gency situation: – IImplementation of facilities intended for the

recovery of materials, fuel and energy fromwaste matter

– Achievement of the collection of waste matter and differentiated collection

– Promotion of the transport system for wastematter and establishment of the related rates

– Security measures for dumps (some of whichwere illegal)

– Interventions related to environmental clean-up

The audit revealed that the management is stillbeing conducted as if it were an emergency situa-tion, even though this is no longer the case.Furthermore, the explicit target of collecting 35%of the material by differentiated collection has notbeen achieved.

The Italian SAI concluded that the results achievedseemed to be inconsistent and surely inadequatewith reference to the estimates made by the ma-nagement, when the time that has elapsed andthe resources to which the management had ac-cess are taken into account.

5.6 Topic 6 – Compliance with national lawWhen dealing with environmental issues, the focusis usually on compliance with laws and regulationsspecific to this domain. However, one should bear inmind that environmental fields need to be conside-


red from other angles as well, such as the perspec-tives of health and safety and of accounting lawsand regulations. Therefore, when dealing with envi-ronmental matters, it is important that all of the re-levant laws and regulations be considered.Requirements often associated with financial auditshave a natural place here. SAIs that do not have amandate for performance auditing often use compli-ance with legislation and general quality require-ments as a justification for environmental auditingas was done in the Chilean example below.

Furthermore there are laws against eco-criminalitythat should be considered.

The SAI of Hungary published in 2001 an audit ofthe operation of the Central Nuclear Financial Fund.In this audit, the SAI evaluated the lawfulness andexpedience of the operation and financial manage-ment of the Central Nuclear Financial Fund for1998, 1999 and the first half of 2000. The auditincluded a review of the establishment and opera-

tion of the storage facilities for radioactive wasteand burnt-out fuel.

The law that governs the safety and protection ofthe local population and the environment regulatesthe use of nuclear energy in Hungary. According tothis law, it is the task and responsibility of the go-vernment to manage and control the uses of nu-clear energy. The government has delegated thesefunctions and tasks to the National Nuclear EnergyCommittee, the National Nuclear Energy Office anda number of ministers. The law also includes provi-sions concerning the financing of task perfor-mance through the Central Nuclear Financial Fund,which had revenues of HUF 22,964 million and ex-penditures of HUF 8,342 million in the audited pe-riod. In order to ensure the safety of the uses ofnuclear energy, the government commissioned thenational office to set up the Radioactive WasteManagement Company as a public company tooperate radioactive-waste storage facilities. Thiscompany is also in charge of establishing storagefacilities.

Bjørn Rørslett / NN

/ Samfoto


One of the findings was that resources from thefund were not only spent on research and explora-tion to select sites for final storage for low andmiddle level radioactive waste, but also on promo-tional activity to gain public support. The fund alsofinanced experts who were supposed to find a sui-table site for establishing the storage facility forHigh-Level Radioactive Waste. This research acti-vity was cancelled after the government rejectedthe idea of deep exploration, because the rese-arch could continue from the surface with greatercost efficiency.

Another finding in this audit was that in two regionsand in several projects32, the cost of promotionalactivities to gain public support for existing and fu-ture radioactive storage facilities had been recor-ded in the accounts among the cost items for rese-arch and exploration work. This is in breach of therelevant regulations in the Accounting Act.

The SAI of Chile audited in 1999 the manage-ment of waste from households, industries andhospitals using compliance with national legisla-tion as a justification.

Solid waste originated by householdsThe audit revealed that 72% of the country’s land-fills did not have the required authorisation basedon appropriate resolutions. 30% of the landfillswere illegally located too close to residentialareas, putting local populations at risk.

Audit inspections carried out at specific landfillsrevealed that 42 % of the contractors of thoselandfills did not comply with their contracts. Theaudit also revealed that 65 % of the examined sites did not have a proper register confirmingthat the collected waste was in fact deposited atthe landfill. Another finding was that some regionshad non-registered micro-landfill sites, which posea risk to the populations around them.

83 % of the examined landfill sites had also failedto maintain an updated register of the health ser-vice’s inspections. The rest of them had not yetestablished a proper register in which the inspecti-ons to which they are submitted can be noted.

It was also found that 54% of the landfills receivedsolid waste from industry and hospitals and alsoradioactive waste, and 41% of those landfills did

not have registers that showed the kind of wastethey had received.

The audit also reported that in several regions dif-ferent critical studies of waste management hadbeen carried out, but the good performance recom-mendations proposed in the studies had not beenimplemented. These studies had been financed bynational and international aid funds.

Conclusions with regard to household waste– The audited regional public health services and

municipalities have shown that they have not fully complied with their control obligations, usually because of a lack of resources, instituti-onal policy, a lack of coordination and/or insuf-ficiencies in the legislation.

– The regional public health services have notcomplied with their control obligations related to the minimum sanitary norms that any dum-ping site must fulfil in order to avoid danger tothe sites’ workers and the public in general.

– The municipalities have not complied with their own control obligations derived from the basic law of Municipalities, which prescribes obliga-tory measures for developing and preserving environmental quality in their own areas.

Industrial wasteThe Regional Health authorities’ registers of indus-tries that generate dangerous waste were insuffici-ent in most regions. In some regions, there wasno reliable register. The registers also lacked infor-mation about the amount of waste and its relativedegree of danger. In some cases, the final destina-tion of the waste was unknown. The regional offi-ces of the Auditor General in Chile confirmed thisinformation by control auditing a sample of 97 in-dustries.

In 33% of the industries visited in the sample, insome cases the waste was transported to illegaldumping sites either by the industry itself or by contractors. In these cases, it was not possible toidentify the final destination of the industrial waste.Thirty-five of the 97 audited industries did not havethe required sanitary permits for the transport, treatment or final disposal of their waste.

Only a few of the regions provided specially delimi-ted areas for industrial waste disposal at the dum-ping sites. In most regions, there were no suitablelocations for industrial waste at the landfills.

32 The Fund’s investment projects for the intermediate deposit sites for burned-out elements


Given the absence of adequate, legal dumping si-tes and waste treatment companies in most regi-ons, the industries usually chose to dump theirwaste at unauthorised sites, causing a diversity ofenvironmental problems and the contamination ofthe surface and ground water. At some sites, therewas a high risk of spontaneous combustion.Furthermore, the industries usually contravenedthe legal requirements that they declare the kindand amount of waste that they generated.

The audit stated that the health authorities havenot required the audited industries to comply withsanitary regulations. Inspection activities are alsotoo infrequent to provide an adequate level of con-trol.

Waste from hospitalsThe audit examined 45 public hospitals, approxi-mately 24% of all public hospitals in the country.Another 36 health-care establishments, includingprivate hospitals and clinics, emergency units, me-dical consulting rooms and policlinics, were alsoinspected.

Most of the health care services in Chile do nothave clear regulations specifying how to managetheir waste, other than regulations to prevent andcontrol infections in hospitals and other healthcare establishments. The investigation revealedthat in 1998 a regulation governing waste treat-ment to prevent infections issued by the HealthMinistry’s Division of Human Health was abolishedthree weeks later by the same ministry’sEnvironmental Health Division. After that, the mat-ter had not been regulated again33.

The study uncovered that biological and surgicalwaste is often incinerated and then deposited at amunicipal landfill, with or without the required per-mits from the sanitary authorities. Voluminous bio-logical waste is usually buried in a common pit atthe local cemetery.

In the public hospitals in two regions, the biologi-cal, surgical and chemical waste was incineratedin technically unsuitable incinerators, spewing toxic fumes into the atmosphere. In these regions,there is only one hospital with an adequate incine-rator. Unauthorised incinerators were observed insome regions. In addition, some of the regionsthat did have incinerators did not utilize them inconformity with the regulations.

The hospital waste in one region was disposed ofin an abandoned mine, posing risks to the environ-ment and the local population. The place was notproperly sealed and sanitarily secured, and no war-ning had been issued to people in the vicinity. Inanother region, the audit revealed that a hospitaldisposed of its waste in an old well in its backyardonly two meters from the staff’s cafeteria.

Misconduct was also discovered in practices rela-ting to outdated pharmaceutical products. 12% ofthe sanitary institutions delivered the outdated me-dicines back to the producer; some users incinera-ted the outdated products and then disposed ofthe ashes at a landfill; and others dissolved theseproducts in water and emptied them into the se-wer system.

When it came to the control of radioactive substan-ces, the audit revealed that the authorities failedto regularly monitor users, to make sure that theradioactive waste generated and the abandonedequipment had been safely treated and stored.

Other shortcomings that were found included: – Poor labelling of boxes containing hospital

waste– Defective bins– Insufficient protection of staff responsible for

the temporary transport and storage of this waste

– Insufficient access control to temporary storageinstallations and incinerators

Conclusions regarding hospital wasteThe current sanitary legislation includes very fewregulations pertaining to the management of wastefrom hospitals and other health care establish-ments. The Health Services have not compliedwith the requirements of the law, and the Ministryof Health has failed to achieve its aims in a pro-perly co-ordinated and unified way as specified inthe General Provisions pertaining to GovernmentAdministration.

The Austrian SAI published in 2001 a report con-cerning the waste management activities of theorganisation that carries out these activities inLeoben in Austria. The organisation was established in 1988, and by1991, 17 communities were members. Since theorganisation did not have any treatment facilities of

33 As of the year 2000


its own, the handling of the waste was delegated toa private company for an unlimited period. Later, thecontract was renegotiated, and on this occasion theorganisation succeeded in obtaining the cheapestprice for the waste treatment in the region.

Due to the delay in payments from the participa-ting counties, the organisation had to draw onsome of its reserves. In order to overcome thisproblem, the SAI suggested the introduction of in-terest on overdue payments, among other things.

Because of waste separation and preventive mea-sures, residual waste was reduced in the period1992 to 2000 from 13,300 tonnes to 9,600 ton-nes. However, the overall volume of waste increa-sed in this period from 24,500 tonnes to 26,000tonnes. In this respect, the SAI is of the opinionthat the need for separation of waste should beemphasised to those who generate waste.

The Austrian SAI concludes its report by statingthat the organisation’s structure is in accordancewith the requirements and is efficient.

The SAI of the Czech Republic conducted in 1996an audit of the selection and utilisation of finan-cial instruments in the field of waste manage-ment. One aim of the audit was to verify the collection ofrevenue in the waste management system and theefficiency of their use for waste disposal togetherwith funds provided from the national budget andthe State Environmental Fund. The auditees weregovernment administrative bodies (the Ministry ofthe Environment, the Czech EnvironmentInspection, local financial bodies, municipalities)and landfill operators.

The shortcomings ascertained among the auditeeswere related to violations of waste management le-gislation and unclear interpretations of some of theconcepts used in the legislation. These weaknes-ses usually developed during the classification ofwaste and in the process of assessment and theselection of financial instruments. The consequen-ces were under-fulfilment of revenue targets fromfees and a low number of charged fines.

The Czech Environment Inspection did not use allof the instruments available during administrativeproceedings, such as the separate management offees and fines. Some of the administrative proce-dures for landfills were not specified or completed,and not all of the audited landfills were subject to

payment. The level of fines resulting from decisi-ons did not correspond to either the amount or thecategory of actual waste in landfill sites. TheCzech Environment Inspection rarely fined landfilloperators, even though the latter demonstrably fai-led to fulfil their obligations.

Audits of the financial bodies involved revealedthat they did not keep the required records of feesand fines, and their accounting procedures werefaulty. There were errors in connection with the col-lection of unpaid fees.

Audited district offices categorised some waste inwaste plans that the official classification and thecatalogue of waste did not allow. They also failedto fulfil other obligations, such as keeping recordsof waste announcements.

There were cases where landfill operators did notpay fees for landfills, or the fees were not paid inaccordance with the regulations. Some landfillswere operated without appropriate approval, with-out operational rules, and without the required records of waste.

The SAI of Malta performed in 1999, a prelimi-nary survey of activities related to the WasteManagement Strategy and the collection of reve-nue at landfills. The Waste Management Strategy ImplementationDepartment (WMSI) is supposed to implement thewaste management policy and guidelines establis-hed by the environmental authorities, and it is re-sponsible for the management of landfills in Maltaand Gozo and for the collection of revenue fromthese sites.

The relevant environmental legislation can be inter-preted as an expression of the government’s "pol-luter-pays" policy. The legislation also enables theDepartment to collate statistics regarding wastemanagement and to nurture and regulate the local"waste collection" industry.

The audit revealed a discrepancy between theamount collected and the expected revenue fromwaste collection activities. This discrepancy arosepartly because the Department did not invoiceusers with the lowest rate-per-tip.

Site inspections at two landfills showed that therewere several weaknesses in internal controls for re-venue collection and statistical purposes related tothe data on users and the type of waste deposited.


A system for the collection of statistics regardingthe amount of waste deposited at privately opera-ted sites had not been adopted by the Ministry of Gozo.

The SAI of Malta concluded that the issues high-lighted in the report might be hindering the attain-ment of objectives established by the legislation.The potential loss of revenue to the government isnot just disturbing in its own right, but also be-cause the "polluter-pays" principle is not being ap-plied in all instances.

The lack of internal controls at the data-collectionstage of operations was also disturbing, since asound policy of waste management cannot be ba-sed on incomplete data and information.

The lack of reliable statistics prevents investmentplans for environmentally related sectors frombeing clearly channelled in accordance with theEU’s "acquis" requirements.

5.7 Topic 7 – Compliance with international obligationsInternational agreements and conventions on wasteare important instruments when it comes to preven-ting damage to the environment: It is therefore im-perative that the SAIs keeps parliaments informedof how well executive governments fulfil their inter-national obligations in this respect.

In its most basic form, the audit of compliance withinternational obligations can address the issue of en-suring that the international obligations signed by acountry are fully implemented in national laws and re-gulations. Furthermore, it is important to evaluatehow effectively the obligations are fulfilled and whet-her required measurement and reporting systems arein place and providing correct and timely information.

The audit of international obligations is an area inwhich it is especially useful for SAIs to co-operate.Such co-operation might yield economies of scalebecause SAIs can help each other in the formulationof good audit questions and the collection of back-ground information. It might also be useful for coun-tries – and for the environment – to get an unbiasedview of how well a participant is performing relativeto other participants or to a group of such countries.

The SAI of Poland conducted in 2000 an audit on the management of hazardous waste. Amongthe objectives of the audit was the assessment of:

– compliance with the following focal points of theBasel Convention: reducing the amount of hazardous waste generated, ensuring the avai-lability of facilities for the disposal of hazardouswaste and minimising the transboundary movement of waste.

– progress in the implementation of the National Environmental Policy in the field of priority tasks aimed at reducing the impact of hazardous waste on the environment

– performance by the regional government in the area of granting permits to economic entities for the generation and disposal of hazardous waste, performance by the regional authorities in the area of the collection and redistribution of fees for the storage of hazardous waste and fines for the violation of regulations or adminis-trative decisions relating to the storage of hazardous waste

– supervision exercised by the regional environ-mental protection inspectorates of compliancewith the administrative decisions and environ-mental regulations relating to protectionagainst hazardous waste on the part of entitiesthat generate and receive hazardous waste.

Among the findings were irregularities in the func-tioning of the system of supervision and control ofinternational movement of hazardous waste. Therewere cases where the export of waste through bor-der checkpoints and/or the transport of waste bycarriers other than those specified in the permithad been allowed. Another problem was related tothe transit of waste: the customs authorities didnot keep complete transit registers.

The audit indicates insufficient compliance with re-gulations relating to the protection of the environ-ment against hazardous waste by the administra-tive sectors of government and self-governmentadministrative bodies and by the parts of busines-ses involved in activities related to the generationand/or disposal of hazardous waste.

The entities that generated or received hazardouswaste often conducted their activities without thenecessary permits for the generation and/or dispo-sal of this waste. The regional authorities did nothave sufficient information about the economic entities that were obliged to hold such permits andlacked sufficient information about the entities thatwere obliged to pay fees for the storage of waste.

The audit also indicated the need for strict enfor-cement of regulations related to hazardous wastemanagement by economic entities as well as go-


vernment and self-government administrative bodies. It is necessary to strengthen the supervi-sion by the Environmental Inspection of economicentities with regard to hazardous waste manage-ment and likewise the supervision by theCustoms Authorities and the EnvironmentalInspection of the international movement of hazardous waste.

A summary of the audit is available in English athttp://www.nik.gov.pl/intosai

The SAI of Canada published in 1997 a report onthe control of the transboundary movement of ha-zardous waste. The international agreements usedas audit criteria were the Basel Convention, theCanada–USA Agreement on the TransboundaryMovement of Hazardous Waste and the OECD de-cision on the transboundary movement of hazar-dous waste.

The SAI concluded that Canada does not knowhow well it is meeting its international obligationsto prevent illegal traffic in the transboundary move-ment of hazardous waste.

The Ministry of Environment in Canada is not alwayssure whether shipments of hazardous waste reachtheir final destination or are properly disposed of, orrecycled. While the ministry has made a start in es-tablishing a regime to control the legal transboun-dary shipments of hazardous waste, there is littlechance of detecting illegal traffic of hazardouswaste at border points. Customs officers need moretraining to enable them to recognise hazardouswaste shipments. Effective sampling of potentially il-legal exports and imports is very limited.

The SAI concludes that it is even more difficult todetect the presence of hazardous waste at railyards or marine ports. Relatively few rail contai-ners are examined, whether they are imports or ex-ports. There are no targeted inspections of contai-ners exported by ship.

The SAI also commented that it has taken five yearsfor Environment Canada to begin to enforce theExport and Import of Hazardous Waste Regulations

In auditing this area, the SAI used the following de-finitions of the terms "enforcement" and "compli-ance". Compliance means the state of conformitywith the law. Compliance is secured through twotypes of activity: promotion and enforcement.Measures to promote compliance include the com-

munication and publication of information, consul-tation with parties affected by an act, technical as-sistance and technology development.

Enforcement activities include: – inspection and monitoring to verify compliance– investigations of violations– measures to compel compliance without resor-

ting to formal court action, such as directions by inspectors, ticketing, and ministerial orders

– measures to compel compliance through court action, such as injunctions, prosecution, courtorders upon conviction, and civil suits for recovery of costs

For the purpose of the audit, the SAI distinguishedbetween illegal traffic and administrative non-com-pliance, which is also illegal according to the BaselConvention. Illegal traffic is essentially a seriousenvironmental crime capable of producing dange-rous impacts, including threats to human health.Administrative non-compliance can occur througherror, ignorance, and technical or relatively minoradministrative breaches.

The SAI observed that there are real incentivesfor illegal traffic. There is considerable money tobe made, a low chance of detection, and an evenlower chance of receiving administrative, civil orcriminal sanctions. The disposal of a legal truc-kload of hazardous waste, typically 22 metric ton-nes, may easily cost ten thousand dollars. Thereare also costs for liability insurance and broke-rage, and an approximately 35 to 40-day waitingperiod for completion of the required paperwork.Illegal shipments involve no paperwork and no re-cycling or disposal costs, whether disposed of inCanada or abroad. There is little chance of get-ting caught, given the volume of traffic at the bor-der and the variety of substances that are poten-tially hazardous waste. Even if violators arecaught, infractions of the Export and Import ofHazardous Waste Regulations have not resultedin large penalties.

This report is available in English athttp://www.oag-bvg.gc.ca/

The SAI of the United Kingdom published in 2002a report addressing pollution from ships.Among the issues covered was the question ofwhether the government has ensured that portsand harbours have waste management plans andwaste reception facilities. The MARPOL conventionwas used as basis for developing audit criteria.


Since January 1998, all port and harbour authori-ties have been required to have a waste manage-ment plan and appropriate waste reception facili-ties for dealing with oil residues and oily mixtures,noxious liquids and garbage from vessels usingtheir ports. The Ministry of Transport issued gui-dance on what should be included in the ports’waste management plans.

The responsible government body, the Maritimeand Coastguard Agency (the Agency), initially iden-tified over 600 ports that would be subject tothese requirements. In order to prioritise its work,the Agency drew up a list of 36 major ports, eachhaving a throughput of more than two million ton-nes of cargo a year; 75 intermediate ports wherethere was substantial shipping activity; and around500 small ports.

The Agency set itself a target of approving theplans for all major and intermediate ports byDecember 1999, and for small ports by March2001. It substantially achieved its targets.

The UK SAI also addressed the issue of whetherthe Agency has ensured that waste reception facili-ties are adequate.

The Agency does not have statutory responsibilityfor ensuring that ports and harbours maintain ade-quate waste reception facilities; maritime legisla-tion places the responsibility for this on the har-bour authority. However, the Agency commissionedan independent survey of waste reception facilitiesat 35 UK ports in July 2000 to assess compliancewith the port waste-management requirements,and the results of this survey were satisfactory.The Agency also voluntarily visits a sample of portseach year to assure itself that the required facili-ties are in place.

The use of port waste facilities is usually coveredby the fees that port and harbour authorities chargevessels for using their ports. The master of a ves-sel faced with inadequate or no reception facilitiesshould bring the alleged inadequacy to the attentionof the port concerned and of the Agency for investi-gation. Seven cases were reported to the Agencyover the two years from April 2000 to March 2002.The Agency identified deficiencies in four cases andrequired the operators of the ports to improve theirwaste-handling procedures. The facilities werefound to be adequate in the other three cases.

The full text of this report is available in English athttp://www.nao.gov.uk

5.8 Topic 8 – Monitoring The term monitoring covers the activities of govern-ments to oversee practices related to waste hand-ling at different levels and the different instrumentsthat governments use to ensure compliance with le-gislation, concessions and goals related to waste.

First, there is need for information. There has to bea system that provides the government with rele-vant, reliable, valid information about the differentactivities related to waste management. This mayimply the existence of a system that ensures a sa-tisfactory flow of information, such as reporting pro-cedures. Furthermore, the information needs to beof sufficient quality with reference to the purpose. Ifthe information is statistical, the quality of the pro-cedures for collecting the basic material and punc-hing and processing the data must be satisfactory.The Bolivian example below reveals inadequacies inthe general system of monitoring.

Secondly, monitoring implies a system of control.Inspections or the physical presence of people con-trolling waste sites such as installations, plants,landfills etc. are a core activity in this respect.Monitoring may involve checking systems of internalcontrol. These systems require good proceduresand must be put to use in a proper manner. Theycan be subject to supervision by relevant govern-ment bodies. If the monitoring agency does not havethe capacity to inspect all agencies and activities,the decisions on what to inspect must be based ona calculation of the risks entailed for the popula-tion’s health and the environment.

The German audit below emphasises the insuffici-ency of setting goals without establishing controlroutines and criteria for measuring the attainment ofthose goals.

The third element of monitoring is the use of policy in-struments when noncompliant practices regarding le-gislation and good management are discovered.These can be information or recommendations, butcan also be coercive measures such as fining, closinga waste site, withdrawal of a licence or permit or in-structions for further practices. Agencies may have theauthority to enforce licence terms and to prosecutethose who are handling waste illegally. The Norwegianaudit focuses on the unwillingness of the responsiblegovernment body to employ coercive measures.

The SAI of Norway audited in 2001–02 the mana-gement of old hazardous waste sites, studying inparticular whether the clean-up of sites had resul-


ted in the fulfilment of the goals set by the govern-ment and whether the environmental authoritiesensure that the liable owners clean up their sites.

Considerable amounts of hazardous waste havebeen stored without the necessary safeguarding orcontrol at various sites around the country over theyears. Hazardous substances have contaminatedthe environment through leakages and spills fromindustrial activities. The clean-up of such pollutionbecame a government priority in the early 1990s.A nationwide survey of polluted sites was underta-ken in 1989–91, and about 2,500 locations whereidentified. Since then, another 1,000 sites havebeen identified.

The sites have been classified into four groups,depending on the severity of the pollution. The SAIof Norway studied the sites classified as "themost severely polluted", a total of 151 cases. Theaudit showed that a number of sites were incor-rectly classified or overlooked in the original sur-vey. In addition, several cases were described as"closed", even though the sites had not been suf-ficiently cleaned up.

The audit also revealed that the environmental aut-horities have revised and scaled down their goalsfor cleaning up these sites several times. In thegoals adopted in 1999, one of the major objecti-ves was to clean up the most severely polluted si-tes by the end of 2005. However, the audit questi-ons whether this goal will be met.

In many cases, the actions imposed on the liableowners by the environmental authorities were notimplemented. The SAI of Norway’s investigationestablished that the environmental authorities arereluctant to use the coercive measures specifiedin the Pollution Control Act.

The SAI of the United Kingdom published in 2002the audit "Protecting the public from Waste"The Environment Agency (the Agency) regulates themanagement and disposal of over 170 million ton-nes of waste produced by homes, commerce and industry in England and Wales each year. Around 45 % of this waste goes to landfills, including 80 %of the household waste; the rest is recycled or inci-nerated. The audit report focuses on the Agency'sinspection and licensing work in England.

The Agency was established in April 1996, takingover responsibility for waste regulation from 83 localwaste regulation authorities. It regulates waste wit-

hin a legal and policy framework established by theDepartment for Environment, Food and Rural Affairs(the Department) and reflecting European Union le-gislation. This framework sets out the responsibili-ties of producers and handlers of waste, and requi-res the more significant waste sites and activities,such as landfill sites, to be licensed. Other sitesand activities must be registered with the Agency,providing much less control than a licence.

Some 7,700 waste sites and activities are cur-rently licensed, and a further 54,000 sites and67,000 waste carriers and waste brokers are re-

Thomas Tolstrup / Samfoto


gistered with the Agency. The legal framework pro-vides for the Agency to regulate waste in threemain ways: by setting out how waste should bemanaged, e.g. in terms specified in licences; bymonitoring to check compliance with licences andthe law, primarily by inspecting waste sites and ac-tivities; and by dealing with problems, e.g. by pro-secuting those disposing of waste illegally.

Recent European Union legislation has increasedthe Agency's workload, and more is expected to doso in the near future. The Agency is therefore seek-ing to modernise its approach to waste regulationin order to release staff to help to deal with thisnew work.

The Agency has made much progress since 1996in creating a single organisation providing consis-tent and professional regulation across the country.Nonetheless:– The Agency could make better use of the

resources it uses to inspect waste operators,improve the effectiveness of regulation, and reduce unnecessary regulatory burdens, by carrying out fewer but more comprehensive andin-depth inspections.

– The Agency needs to deal more effectively withoperators that persistently fail to comply with their licences. The Agency has become increasingly active in prosecuting waste offences but needs touse its enforcement powers more effectively

– The Department recognises that controls over sites exempt from the requirement to be licen-sed need to be changed, e.g. to bring some cur-rently exempt types of sites within the scope oflicensing, and to exempt others that are cur-rently licensed, but it has taken too long for theDepartment to complete a review of these con-trols.

– The Agency needs to look for ways of reducingthe time taken to deal with licence applications.

– Taxpayers may end up paying for dealing with pro-blems caused by abandoned waste sites; particularly landfill sites, because operators' financial provisions are either insufficient or unavailable.

– Evidence pointing towards an increase in fly- tipping following the introduction of theLandfill Tax in 1996 is anecdotal, and theAgency’s records do not show a clear trend.However, the Agency estimates that each yearthere are around 50,000 fly-tipping incidents,costing local authorities some £50 million to£150 million to deal with.

This report is available in full text in English athttp://www.nao.gov.uk

The German SAI conducted in 1996 an audit fo-cusing on the fulfilment of environmental require-ments tied to investment grants for reducing envi-ronmental pollution and promoting investments inpollution reduction (report VII 7-3002/96).

1. A centre for waste treatment applied for a government grant designed to promote innova-tive practices in waste disposal, arguing that theirconcept of waste utilisation was unique.

Insofar the German SAI concludes: – The project received grants from the govern-

ment, even though the government environ-mental agency (UBA) did not regard any of thetechnical components as groundbreaking orinnovative

– The innovative nature of their concept could beseen in the unique combination of components,but the audit showed that neither the combina-tion of components nor the way in which theywere operated were of an innovative nature.

2. Two of the targets of the project were extensivepublic presentation of the means of operation andthe optimisation of sorting and intermediate stor-age of problematic waste. These targets also con-stituted requirements for the grant.

The communication between the company and thegovernment environmental agency (UBA) was not found to be sufficient with regard to how thegoals should be attained and how effectivenessshould be checked in connection with both ofthese targets.

When the centre’s technical components had beenin use for a while, the degree of attainment ofsome of the goals was studied and reported by thecompany. For example, public relations activitieshad been carried out in collaboration with thecounty authorities. For many other targets, the SAIwas unable to establish that government environ-mental agency (UBA) had followed up the goals ortested goal effectiveness. Insofar, the German SAIconcludes, that:– The project targets had not been researched.– No control of effectiveness was carried out

The German SAI considers this to be a necessarycondition for measuring success and profitability inaccordance with the federal budget regulations. Inaddition, it is emphasised that it is insufficient toset goals without establishing criteria for measu-ring the attainment of those goals and proposingcontrol routines.

The SAI of Bolivia conducted in 2001 an audit ofthe environmental performance of the responsibleentities involved in the final disposal of solid wastein one sanitary filling pit in the city of Cochabamba. The major findings were:The mayor did not have a programme for monitoringbiogas, leachate to subterranean waters, etc. The mo-nitoring activities performed by the municipal wasteservice firm did not comply with the environmentalstandards and were insufficient and inadequate.

In the first half of 1999, the waste service firm didnot manage hazardous hospital waste adequately.In the second half of 1999, it started to place ha-zardous hospital waste in a special cell, but the en-vironmental standards were still not satisfied be-cause of certain operational factors.

The audit also revealed that there were discrepancieswith regard to the reception and treatment of tannerysludge. The inadequate disposal of dry tannery sludgehad caused changes in the ground beneath the

sludge. The regional association had only partly imple-mented the Inter-Institutional Convention for an inte-gral solution for the treatment and final disposal oftannery waste. Some of the necessary constructionhad not been built, and the technical supervision ofthe treatment of sludge was insufficient.

5.9 Topic 9 – Effects of other government activitiesMost economic activities create residues of somesort. Experience has shown that government activi-ties are not necessarily any more environmentally fri-endly than other economic activities. In many coun-tries, each ministry is responsible for all aspects ofthe activities under their jurisdiction. When ministriesor public enterprises are involved in investment pro-jects, production or the delivery of services it is una-voidable that waste will be generated. This wastehas to be managed in a professional manner. Typicalsectors in which government activities producewaste include: transport, defence, the construction


River polluted from household waste. Fredrik Naumann / Samfoto


of public buildings and infrastructure, oil and energyproduction, and the provision of hospital and otherhealth-related services. It should also be noted thateven the government bureaucracy generates wastefrom offices, etc. The SAI should perform audits toensure that the government as a producer complieswith the applicable laws and regulations relating tothe minimisation and disposal of waste in a way thatis as efficient and economic as possible.

Another problem that may be addressed is to ensurethe inclusion of waste management costs in budgetsand specifications. In compliance with Principle 16 ofthe Rio Declaration, nations should take "into ac-count the approach that the polluter should, in princi-ple, bear the cost of pollution". This is also calledthe polluter-pays principle and constitutes a soundapproach to economic activity in general – the clean-up costs should be acknowledged and visible in ac-counting documents. In countries that only practicecash-based accounting, it is particularly importantthat future costs of waste management are made vi-sible to the decision-makers and taken into accountwhen decisions are being made. The SAI shouldmake sure that this is indeed the case.

The SAI of the USA examined in 2001 the environ-mental clean-up costs of ongoing operations of theDepartment of Defense (DOD). Clean-up costs arecosts associated with hazardous waste removal,containment, or disposal and include decontamina-tion, decommissioning, site restoration, site moni-toring, closure, and post-closure costs. With the ex-ception of training ranges and weapons systems,the review included all ongoing and inactive/closed

operations at six active installations known to resultin hazardous waste and subject to federal, stateand/or local laws or regulations requiring removal,containment or disposal of that waste.

The objectives were to determine: – The scope of ongoing DOD operations with

potentially significant clean-up costs – The potential magnitude of costs to clean up

and dispose of the hazardous waste resultingfrom those operations

– The availability of data for developing clean-upcost estimates

The audit showed that DOD has not developed poli-cies, procedures and methodologies to ensure thatthe clean-up costs required for all of its ongoing andinactive or closed operations are identified, consi-stently estimated and appropriately reported. As aresult, DOD’s financial statements and environmen-tal reports continue to underreport environmental li-abilities and related long-term budgetary needs.

The military installations that the auditors visitedcomprised a total of 221 sites with estimatedclean-up costs of USD 259 million. Of these sites,only 45 with estimated clean-up costs of USD 61 million were being reported in the DefenseEnvironmental Restoration Program Annual Reportto Congress, and only that amount was likely to beincluded in DOD’s financial statements.

The auditors also found that DOD was not repor-ting 149 sites related to ongoing operations and27 inactive and closed operations. This report, GAO-02-117, is published in Englishat http://www.gao.gov/

1 Definition of waste .................................................................................. 63

2 Classification of waste ............................................................................ 65

2.1 Introduction .................................................................................... 652.2 Hazardous properties ...................................................................... 652.3 Waste producer ................................................................................ 682.4 Chemical and physical properties ...................................................... 682.5 Organic/inorganic ............................................................................ 692.6 Composition ...................................................................................... 692.7 International statistics on waste .......................................................... 71

3 Environmental issues related to waste ........................................................ 73

3.1 Public health ...................................................................................... 733.2 Environmental problems .................................................................... 74

4 Storage, collection and transport ................................................................ 77

4.1 Storage before collection .................................................................... 774.2 Collection and transport .................................................................... 774.3 Special precautions for hazardous waste ............................................ 78

5 Approaches to waste handling .................................................................... 81

5.1 General ............................................................................................ 815.2 Recovery (recycle and reuse) .............................................................. 815.3 Composting – treat and process .......................................................... 825.4 Energy from waste – treat and process ................................................ 835.5 Treatment of hazardous waste ............................................................ 845.6 Landfilling .......................................................................................... 855.7 Costs ................................................................................................ 85

6 Summary .................................................................................................... 87

Properties of wastes which render them hazardous ...................................... 89

Background Orientation on Waste1


1 This text is written by a team from Norwegian Resource Centre for Waste Management and Recycling under the supervision of the Office of the AuditorGeneral of Norway.

Appendix 1

Kiyoshi Okamoto/IDI

This chapter describes some of the difficulties indistinguishing between product and waste. In a hou-sehold or a small business, the definition of wasteis relatively straightforward, but in a processingplant, the distinction between product and waste isnot always clear.

Most of us would probably define waste as a pro-duct or substance that is either damaged beyond re-pair or is no longer usable. In other words, waste issomething that is no longer of any use to you, soyou might just as well part with it.

This definition is fine as long as you are only dealingwith goods that are intended for consumption, but inthe processing and manufacturing industry this defi-nition soon becomes unusable. Here, large quanti-ties of a wide range of substances flow into, out ofand between plants, making it difficult to distinguishbetween raw material, by-product and waste.

In many cases a substance that is no longer usablein one plant, can be used for a totally different pur-pose in another plant, with excellent results. With re-gard to the definition given below, it could be arguedthat the substance is no longer usable for its inten-ded use, and hence should be regarded as waste.The holder of the waste, on the other hand, would ar-gue that the used substance is a product (i.e. notwaste) since it is usable in another plant. If the hol-der of the waste gets paid for the product, it is evenharder for him to regard the substance as waste.Most people are used to thinking that somethingthat you can get paid for must be a product.

To sort this out, a legal definition is needed. Mostcountries have adopted some form of definition ofwaste, which varies throughout the world. It wouldbe beyond the scope of this project to list all the de-finitions that are in use today, but in general theyare all based on the term "discard", i.e. somethingwhich the holder intends to get rid of or has got ridof. In the Basel Convention (www.basel.int) waste isdefined as "substances or objects, which are dispo-sed of or are intended to be disposed of or are re-quired to be disposed of by the provisions of natio-nal law". Another definition of waste is a product nolonger suited for its intended use. The value of the

object plays no role in defining whether an object iswaste or not.

One of the most extensive definitions can be foundin the European Union, where waste is defined in di-rective 75/442/EEC as "any substance or objectset out in annex I which the holder discards or in-tends or is required to discard". Annex I contains 16categories of waste, numbered from Q1 to Q16.Some examples are:

Q2 Off-specification productsQ6 Unusable partsQ7 Substances, which no longer perform

satisfactorilyQ13 Any materials, substances or products whose

use has been banned by law

These definitions may seem relatively straightfor-ward at first glance, but several factors complicatethe picture. In the example above, we saw that it isnot natural to regard something that is most defini-tely useful as waste. Another complicating factor isthat a substance can be defined as waste at onepoint in time and as a product at another time, ifthere is a demand for it on the market.

The example of timber illustrates a well-known pro-blem in the processing industry: a large number ofchemical components can be extracted from timber.Since the chemical composition of timber is relati-vely constant, the amounts of components as wellas the relative quantities in which they are producedremain constant. In Scandinavia, the wood-proces-sing industry has developed an "eco-system" bet-ween various components derived from the log flowbetween plants on opposite sides of country bor-ders. As long as there is a demand on the marketfor a certain component, it can be sold as a pro-duct. If the demand diminishes or ceases comple-tely, the producer has to get rid of it in other ways,i.e. he may have to pay to have it destroyed aswaste. In other words, a fluctuation in the marketmeans the same substances can be products atone time and waste at another.

If you consider a processing plant as a black boxthat consumes raw materials in one end and gene-

1 Definition of waste


Appendix 1

rates one or more products in the other, not all theraw materials will come out as products. The fracti-ons of the raw materials that have not been used orthat have been chemically transformed into compo-nents for which there is no use can be classified aswaste or by-products depending on market demandand/or legislation. In general, the authorities regu-late waste more strictly than products. This is espe

cially true when waste is to be moved from onecountry to another. If a use can be found for a sub-stance that has hitherto been treated as waste, theholder of the waste can face major difficulties inconvincing the competent authorities that the sub-stance is no longer waste, but a product that shouldbe moved freely without restrictions.


This chapter describes various ways of classifyingwaste. Most often, waste fractions are classified ac-cording to generator and/or hazardous properties,but classification can also be based on compositionand chemical/physical properties.

2.1 IntroductionMany parameters can be used to describe waste,and depending on your role in the waste theatre,some will be more important than others. For a le-gislator, the distinction between hazardous and non-hazardous waste may be one important parameter,since legislation regarding hazardous waste is usu-ally stricter than for non-hazardous waste. For a tre-atment plant, composition may be more important,simply because some types of waste are not treata-ble in that specific plant.

The most common parameters used to classifywaste are:

1. Hazardous properties2. Generator3. Chemical and physical properties4. Organic/inorganic5. Composition

These parameters will be discussed in more detailbelow. When reading the description, bear in mindthat in many cases the parameters overlap and aredependent on each other. The hazardous propertiesof waste are highly dependent on the composition ofthe waste, which is again dependent on the produ-cer of the waste, and so on.

2.2 Hazardous propertiesHazardous waste is waste that can be harmful topeople or the environment. Examples of hazardousproperties are listed at the back of appendix 1.Waste that does not display any of these characte-ristics is classified as non-hazardous.

In many cases the distinction between hazardousand non-hazardous is not intuitively obvious. For in-stance, diesel fuel is regarded as flammable, whe-reas paper is not, even though paper burns vigo-

rously. Ordinary table salt (NaCl) is not consideredtoxic, but intake of large amounts of salt is never-theless lethal. The reason for this can in many ca-ses be found in the testing methods that are usedto determine whether an object is hazardous ornot.

2 Classification of waste


Bjørn Rørslett / NN / Samfoto

Appendix 1

International classification standards

In the 1980s, two international organisations deve-loped classification systems for hazardous waste.They are the Basel Convention (www.basel.int)2 andthe OECD (www.oecd.org).

The Basel Convention is an international diplomaticconvention that has been ratified by most countriesin the world and has thus become a de juro stan-dard. The convention governs international transportand disposal of hazardous waste and includes a listof 45 waste streams ("Y-numbers") and hazardousconstituents that should be controlled.

OECD (The organisation for economic co-operationand development) is an international organisationthat helps governments tackle the economic, socialand governance challenges of a globalised eco-nomy. OECD has established a far more extensivelist, which also includes non-hazardous waste. Withreference to traffic lights, waste is divided into threecategories; green, amber and red. The green list in-

cludes non-hazardous waste products such as pa-per, plastics, glass and metals in their reducedstate. The amber list includes most hazardouswaste, while the red list is reserved for highly hazar-dous waste such as PCB, PCT, asbestos and leadcontaining anti-knock fuel additives. It is worth no-ting that for certain types of waste to be included inthe green list, they have to be in a non-dispersiblestate. This means that powders and liquid solutionsare considered hazardous even if the solid materialitself is not hazardous.

Physical/chemical hazardous propertiesSome types of waste have properties that can beharmful to people, living organisms and/or the envi-ronment. Common examples of hazardous propertiesare flammable3, toxic, explosive, corrosive, ecotoxicand infectious. Such waste is called hazardous waste.

Chemical waste is an inaccurate term that is oftenused to describe the hazardous fraction of industrialwaste. It is a synonym for hazardous waste.


Hazardous waste. Car batteries and battery oil. Ove Bergersen / NN / Samfoto

Hazardous waste is not necessarily more harmful aswaste than when it was a product, but if hazardouswaste is not taken care of properly, it may pose athreat to human health and the environment. Forthis reason, many countries have strict regulationson the storage, collection and treatment of hazar-dous waste.

Some waste may need special treatment becauseof its physical properties, even though it does nothave hazardous properties. Three such propertiesare liquid, gaseous or powder. Such waste needsspecial handling to avoid unwanted dispersal of thewaste. One good example is an ordinary householdfire extinguisher. It consists of a metal cylinder filledwith a non-toxic gas and a powder. If released in aconfined space, the gas will offset the oxygen ba-lance in the room and may lead to fatal breathingdifficulties. If the gas is released quickly the cylinderitself can be cooled down to a point where touchingit can lead to serious frost injuries. Finally, the pow-der, although not toxic, can be harmful because itclogs the pores in the lungs and prevents oxygenfrom entering the blood stream.

Asbestos is another example. Asbestos is a groupof naturally occurring minerals that have none of thehazardous properties mentioned above, and whenexposed to sun and rain asbestos minerals will we-ather away quickly. The real danger with asbestos isthat it is fibrous and that the tiny strands of the mi-neral can cause lung cancer if inhaled.

Radioactivity

Technically speaking, radioactivity is a hazardousproperty, because exposure to radiation can causeserious illness, or even death. Many radioactivesubstances are also highly toxic. In contrast to "ot-her" substances with hazardous characteristics, ra-dioactive substances are not readily available to thegeneral public. In general, radioactive materials areonly available to scientists, nuclear power plantsand other users who have a specific need for radia-tion in their work. Because of this, radioactive sub-stances are dealt with separately below.

Radioactivity is a naturally occurring process, which iscaused by instabilities in the core (nucleus) of anatom. Each atom in the universe has a core that con-sists of one to about 115 protons. In addition, therewill be a number of neutrons in the core, ranging fromzero to about 200. Only certain proton/neutron com-

binations are stable, and an atom with an "illegal"proton/neutron ratio is unstable. To regain stability,the atom can either emit energy (gamma radiation) orit can get rid of the overload by offloading excess par-ticles in the core. This is called particle radiation.

Releasing a particle or a gamma unit is called disin-tegration. One disintegration per second equals oneBequerel (Bq). Bq is a measure of the activity of aradioactive component and is often expressed rela-tive to mass, volume or surface units, such as Bq/gor Bq/l.

Examples of particle radiation are alpha, beta (elec-trons) and neutrons. The "softest" type of radiation,alpha, will not even go through a single sheet of pa-per. If inhaled, however, it can cause lung cancer. Atthe other end of the scale, high-energy gamma radi-ation is able to penetrate several feet of lead. In ad-dition to the hazards connected to radiation, manyradioactive materials are also highly toxic.

Each individual atom will continue to emit differenttypes of radiation several times until it has reachedstability and the radiation eventually dies out. Sinceradioactivity is so closely connected to the conditi-ons in the interior of the atom, there is no way todestroy it. The only way to treat radioactive waste isto separate the highly radioactive fractions from theless radioactive fractions, place the waste in tightcontainers and store them until the radiation has re-ached a non-hazardous level. Depending on the typeof atom this process can take anything from micro-seconds to millions of years. Storage usually meansstorage in stable geological formations several hun-dred metres underground.

Although many people associate radioactivity withnuclear power plants and atomic bombs, radioacti-vity is a natural process that has existed ever sincethe universe came into existence. For instance all ty-pes of life, including human beings, contain radioac-tive components.

Typical sources of radioactive waste are

• Nuclear warheads• Waste from nuclear power plants• Build-up of low-radioactive deposits in

tubes (scale)• Waste from hospitals (cancer treatment, etc.)• Other scientific and technical uses


2 The Basel Convention on the control of transboundary movements of hazardous waste and their disposal adopted by the conference of the plenipotenti-aries on 22 March 1989.

3 It may be worth noting that the words "flammable" and "inflammable" have the same meaning in English – to catch fire and incinerate.

Appendix 1

Waste from the two first sources are normally undertight political and regulatory control, and most coun-tries have established systems not only to take careof the waste, but also to guarantee that radioactivematerials will not get into the wrong hands.

Legislation regarding the other types of waste canvary from country to country, but in most countries,all activities associated with radioactive materials(production, ownership, usage, storage, etc.) requirea permit from the competent authorities. People whopossess radioactive materials are also required totake necessary steps to prevent radiation. This inclu-des proper storage and handling of waste. Since ra-dioactivity is a naturally occurring phenomenon, legis-lation also includes limits for when the radiation levelis so low that legislation no longer applies.

Infectious waste. Clinical and medical waste

This is waste from treatment of diseases in humansand animals. This type of waste usually consists ofmedicines, sharp objects, bandages, body fluidsand body parts (from amputations and surgery). Thistype of waste usually contains bacteria and other or-ganisms that can spread harmful diseases if not ta-ken care of properly. It can be said that clinicalwaste is "alive" and therefore needs special treat-ment such as incineration or high-temperature treat-ment to kill or disable the bacteria.

2.3 Waste generatorsWaste can also be classified according to who gene-rated it, for instance:

• Household/domestic• Commercial (from offices/small businesses)• Industrial• Mining

The main reasons for this distinction is that house-holds generate relatively small amounts of wastewith a heterogeneous composition and becausemost councils/counties provide a system for collec-tion and transportation of waste. The term includesall waste from the household’s day-to-day activities,such as paper, plastics, food, etc. as well as largeritems like clothes, utensils, furniture, etc.

Industrial waste, on the other hand, comes in lar-ger quantities and generally has a more homogene-ous composition that reflects the type of activity itoriginates from. A sawmill will generate largeamounts of sawdust, and it can be worthwhile es-tablishing special routines to handle the waste.The amounts can often be so large that the coun-

cil/municipality is unable to take care of thewaste. Handling of industrial waste is often the re-sponsibility of the owner/producer. Large, homoge-neous quantities of waste have a high potential forrecycling, and are rapidly becoming lucrative busi-ness in many places.

The composition of commercial waste can vary bet-ween the two aforementioned extremes depending onthe type of business. In many cases, waste from smallbusinesses has the same composition as householdwaste, and the two can often be handled together.

Mining waste consists of large amounts of rockfragments that are deposited outside the mine. Thesize of the fragments ranges from millimetres to me-tres. The life span of a mine can be more than ahundred years, and in that period several thousandcubic metres of masses will be drilled out and depo-sited. In some cases the waste consists of relativelyharmless rock fragments, but in other cases largeamounts of harmful heavy metals (which occur natu-rally in all types of rock) can be released into the en-vironment. Examples of such metals are mercury,cadmium, lead and copper.

2.4 Chemical and physical propertiesIt is important for treatment plants to have know-ledge of the physical and chemical properties of thewaste, so that they treat it properly. Some importantproperties are:

Calorific value: the amount of energy per kilogramof waste. The higher the energy content, the morevaluable the waste is as a fuel. It also means thatthe waste is less likely to be reused or recycled, foreconomic reasons. Selling the waste as a fuel isusually more lucrative than having it recycled.

Density: the ratio between the mass and volume ofthe waste. This is important for most aspects ofhandling and design of treatment plants. Lightwaste requires large storage volumes and more ve-hicles to transport it.

Grain size: An important parameter for all aspects ofhandling. Small grains are more prone to be sweptaway by the wind and thus more difficult to keep inplace.

Moisture content: water content in percent. High wa-ter content usually means higher treatment costs,since the waste will be less useful as a fuel, and be-cause in most cases the water needs to be treatedbefore it can be released to sewage or a recipient.


Solubility: the amount of matter that can be dissolvedin one litre of solvent, usually water. If waste is solu-ble in water, landfilling can be complicated becauserainfall will transport the waste out of the landfill.

Specific weight: see Density.

Viscosity: a measurement of the toughness or pum-pability of the waste. Syrup has a higher viscositythan water.

2.5 Organic/inorganicThe distinction between organic and inorganic mat-ter is fundamental in chemistry, and hence also forwaste treatment.

The formal difference between organic and inorganicmatter is that organic matter contains carbon4, whe-reas inorganic matter does not. The reason why theterm "organic" is used is that in the past chemistsdistinguished between components derived from li-ving ("organic") and non-living organisms. In mostcases, components derived from living organismscontain carbon, whereas components from non-livingorganisms do not.

The greatest diversity and complexity is found in or-ganic components, which can range from relativelysimple components such as sugar, through highlycomplex structures such as human DNA. Both caneasily be broken down by bacteria, and are not con-sidered hazardous. Another example is PCB (poly-chlorinated-biphenyls), which has a relatively simplechemical structure, but is highly toxic and can onlybe destroyed through incineration at temperaturesabove 1100 ˚C.

Table 1 summarises the major differences betweenorganic and inorganic components.

For other parameters, such as chemical stability, toxi-city and irritability, few generalisations can be made.

Figure 1 on page 70 shows the composition of hazardous waste in four different parts of the world,with organic/inorganic as the main parameter.

Although this is a relatively simple presentation,some information can be deducted from the figure.For instance, the high percentage of organic wastein the richest parts of the world (OECD) is a sign ofa highly industrialised society, where the industry re-fines organic raw materials into complex and highlyspecialised products.

2.6 CompositionIn short, composition is a description of the contentsof the waste. A large number of terms can be used,which vary from general terms to more specificterms. In addition to providing important informationto the people that are going to handle the waste, thecomposition of the waste can also tell us moreabout the people who originally generated the waste.

The compositional terms that are used can vary alot, from relatively simple descriptions in terms oforganic/inorganic to more complicated schemes,using many or all the constituents, such as paper,plastics, glass, metals, etc.

For other purposes, it can be useful to look more clo-sely at the specific components of the waste. This isbecoming increasingly important now that more and


4 By contrast, carbonate (CO3) is not considered an organic component.

Feature Organic Inorganic

Major constituents Carbon Metals are common

Chemical complexity Varies from quite simple to Usually simple (with the exception highly complex of silicate minerals)

Energy content Usually high (with the exception of Usually low, but can be reactive.water). Chlorinated components oftenrequire energy (i.e. high temperatures) to be destroyed.

Flammability Flammable Not flammable, but certain components containing oxygen can support combustion and are highly reactive because of this.

Type of treatment Incineration, chemical or biological. Physical or chemical.

Table 1: Summary of major features of organic and inorganic components.

Appendix 1

more waste streams are recycled and/or the genera-tor is assuming responsibility for the proper handlingof the waste. Some examples of components where itcan be useful to study their individual contribution are:

Non-hazardous components:

• Paper• Plastics• Glass• Metals• Beverage cans

Hazardous components:

• Waste oil (used lubricants with an energy content comparable to heat oil)

• Electronic and electric equipment (EE waste)• Lead acid batteries

To illustrate some of the information that can be deduced from information on composition andamounts of waste, we will start by looking at Table 2that shows the average composition of householdwaste for low, medium and high-income countries.


100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

OECD Middle

East/Africa

Eastern

Europe

Asia/Pacific

Misc. /Sludges

Inorganic

Organic/Oily Wastes

Figure 1: Composition of hazardous waste in various parts of the world. Source: the ISWA/UNDP report "Waste Management", ISBN-92-807-2194-2.

Parameter Low-income Medium- High-income countries income countries

countries

Contents: Organic (putrescible), % 40 – 85 20 – 65 20 – 30Paper, % 1 – 10 15 – 30 15 – 40Plastics, % 1 – 5 2 – 6 2 – 10Metal, % 1 – 5 1 – 5 3 – 13Glass, % 1 – 10 1 – 10 4 – 10Rubber, leather, etc., % 1 – 5 1 – 5 2 – 10Other, % 15 – 60 15 – 50 5 – 20

Physical and Moisture content, % 40 – 80 40 – 60 20 – 30chemical Specific weight, kg/m3 250 – 500 170 – 330 100 – 170properties: Calorific value, kcal/kg 800 –1100 1000 – 1300 1500 – 2700

Table 2: Relative composition of household waste in low, medium and high-income countries (modified from the Asian DevelopmentBank/Norwegian Agency for Development Co-operation (NORAD) project Phnom Penh, Cambodia 2002, available from NORAD).

The most striking difference in waste compositionbetween high and low-income countries can beseen in the contents of paper and plastics, but alsothe content of metals and glass are higher in high-income countries. The relative content of organicmatter is usually much higher in low-income coun-tries. This reflects differences in consumption pat-terns, as well as cultural and educational differen-ces. People in high-income countries, where levelsof literacy are high, tend to read more newspapersand magazines, thus producing more waste. Paper,plastics and cardboard in household waste havemainly been used to wrap goods, and with higher levels of consumption, the amount of packagingalso increases.

The moisture content is closely linked to the contentof organic putrescible matter, reflecting the high wa-ter content in this type of organic matter. Plastics,paper, metal and glass all contain little water. Whenthey become more abundant at the expense of orga-nic matter, not only does the moisture content godown, but also the calorific heat increases since pa-per and plastics both have a high energy content.Table 2 also shows that the specific weight of thewaste is lower, the higher the income. This comesas a result of the higher percentage of paper andplastics in the waste. These materials not only havelower density, but in many cases they also increasethe porosity, i.e. the volume of air, in the waste.Table 3, which shows average values for the dailywaste generation per person (kg/day/person), inlow, medium and high-income countries, further il-lustrates how waste statistics can be used to des-cribe the people who generated the waste.

Table 3 shows that societies with higher incomesand more money to spend buy more products, whicheventually end up as waste.

2.7 International statistics on wasteTwo well-known sources of international waste sta-tistics are OECD and the Basel Convention. Both


Low-incom Medium-income High-income e countries countries countries

Mixed municipal 0.4 – 0.65 0.5 – 0.95 0.7 – 2.0waste, large city

Mixed municipal 0.3 – 0.55 0.4 – 0.75 0.6 – 1.5waste, medium city

Residential waste only 0.2 – 0.45 0.3 – 0.6 0.5 – 1.0

Table 3: Waste production (kg/person/day) in low, medium and high-income countries. Source: Asian Development Bank/NorwegianAgency for Development Co-operation (NORAD) project Phnom Penh, Cambodia 2002, available from NORAD.

Espen Bratlie / Samfoto.

Appendix 1

present waste statistics on their web-sites,www.oecd.org and www.basel.int.

In many cases, the statistics on these web-sites arepresented using data formats and classification codes that require knowledge of their classificationsystems, and for this reason they are of limited value for this paper. International waste statisticsoften have the following shortcomings:

• In many cases, the lack of common, internatio-nal classification standards makes it difficult tocompare figures. It is thus not always clear whattypes of waste are included in the statistics.

• Some member countries do not report, reporttoo late or provide insufficient or incompatibledata.

• Data are not always up-to-date.


Waste that is not properly collected stored or trea-ted not only gives rise to harmful environmental ef-fects, but also poses a risk to public health.

3.1 Public healthThe most serious problem related to waste is thenegative influence it may have on public health. Thisholds especially true for hazardous waste. Not beingaware of the fact that improper waste managementmay cause adverse health problems may be one reason why waste is not managed better in manycountries.

Transmission of diseases and infections

In most developing countries, waste collection is in-adequate. This leads to waste being disposed of onstreets, in backyards, in canals/rivers, etc. Sincemany types of waste contain edibles, it will be a

source of food for rodents and dogs and also be abreeding ground for insects. Rats for instance, havea long history of spreading serious infections, suchas the plague. Night soil and/or toilet paper in thewaste can spread infections such as parasites andworms. Flooding combined with a lack of properstorage bins can create a bacterial soup in the stre-ets where children play.

Healthcare waste, for instance, is as example of awaste stream with a high potential for spreading dis-eases. It contains a wide range of hazardous and toxic materials as well as infectious materials.

Working environment

Figure 2 illustrates how infections and diseases aretransmitted along with waste. People working withcollection, sorting or treatment of waste are natu-rally more likely to be exposed than others. A report

3 Environmental issues related to waste


Water

Waste Soil FoodPeople

Rodents and insects

Hands

Figure 2: The way infections are spread. Source: Asian Development Bank/Norwegian Agency for Development Co-operation (NORAD)project Phnom Penh, Cambodia 2002, available from NORAD.

Appendix 1

from Vietnam5 has showed that infant mortality ra-tes can be as much as seven times higher amongwaste workers than in other professions. Waste ma-nagement authorities must be aware of the pro-blems and implement working routines that reduceexposure, train workers to handle waste safely, andstress the necessity of using protective equipmentsuch as gloves, proper shoes, respiratory masksetc., in order to reduce the risk of people being ex-posed to infections and diseases from the waste.

Collection of waste entails hard physical work, andworkers are often exposed to cuts and bruises fromsharp objects, as well as back and joint injuriesfrom heavy lifting. Some of these problems can bereduced by using bins instead of bags for storage(see section 4.1) and implementing a collection sys-tem where the manual work is reduced through theuse of hydraulic lifting equipment. Where waste issorted manually, this ought preferably to be done onan elevated conveyor belt and in a room with properventilation. The machines used should have a goodfiltering system, and cabins should be overpressuri-sed.

Hazardous waste can pose an especially seriousthreat to the working environment. Workers who arenot wearing protective clothes and a gas mask mayrun the risk of serious injury, for instance as a resultof skin burns from acids or inhaling organic solventsthat can injure the lungs, the liver and other internalorgans. Explosions are also known to have occurredas a result of handling hazardous waste.

3.2 Environmental problemsAs we saw in section 2.2, hazardous waste has pro-perties that make it a threat to the environment ifnot taken care of properly. One example is wasteoil. If released into a water body, it can damage theprotective coat of birds’ feathers and eventually killthem.

Paradoxically enough, treatment of waste can alsobe a source of contamination. Improper handling ofwaste can pollute soil, water and air. This is one rea-son why most countries have regulated the establish-ment of treatment plants for all types of waste; i.e.waste treatment plants need a permit to operate.

Odour, littering, unsightliness, etc.

Some of the problems entailed by waste are relatedto nuisance. One example is the bad odours that ori-ginate from containers or waste left on streets, andthis is one of the reasons why waste must be collec-ted frequently. Frequency depends on a number offactors, including climate and type of waste. A warmclimate and waste with a high-organic content re-quire more frequent collection. Frequency normallyvaries from daily to once a week.

Waste treatment plants, especially landfill sites, canalso be a source of odour problems. During decom-position of organic waste, methane, carbon dioxide


5 "Health & Social Needs of Waste Pickers in Vietnam", Nguyen H.T.L., Chalin C.G., Lam T.M., Maclaren V.W.

Erkki Laine / Gorilla / Samfoto

and a large variety of other gases are released.Some of these are organosulphur compounds,which have a very low threshold for odour. A landfillcan cause loss of amenity and nuisance several ki-lometres away from where it is located.

Littering from waste is more an aesthetic problemthan an environmental problem per se. However,consequences of littering may include waste bloc-king drainage pipes and causing secondary environ-mental problems such as flooding.

Soil

Dust, leachate water and use of products such aspesticides or depositions can cause contamination ofthe soil by emissions caused by uncontrolled burningof waste. Heavy metals are known to have effects onthe nervous system, injure the kidneys and causemental disorders. Other toxic components such aspersistent organic pollutants (POPs such as DDT, dio-xins, PCBs, etc.) remain in the environment and bioac-cumulate through the food chain, posing a risk of ad-verse effects on human health and the environment.

Polluted soil can also damage flora and fauna bybeing toxic itself or by releasing toxic componentsinto the food chain.

Surface and groundwaterRain or surface water seeping through waste will ab-sorb hazardous components and carry them intosurface and groundwater. This water may then be

used for recreation, drinking, breeding of fish, etc.,resulting in negative health effects.

Air, local and global problems In many countries, there was and often still is a habitof setting fire to waste. This may be done in eachhousehold, to communal dumps along streets or atregular dumpsites. The result is incomplete combus-tion, which gives off in toxic and carcinogenic emissi-ons of PAH (polyaromatic hydrocarbons), dioxins, etc.This habit is one of the major sources of emissionsthat are harmful to human health and the environ-ment in general. Scavengers at landfills often set fireto the waste to make it easier for them to find me-tals. Uncontrolled fires in landfills due to self-ignition(often caused by illegal dumping of hazardous waste)are also a major source of emissions to air.

Old or badly operated incineration plants can alsobe a source of hazardous emissions such as heavymetals (mercury, cadmium, etc.) and dioxins. Anaerobic degradation of waste (without oxygen),which normally takes place at landfills, creates alandfill gas that typically consists of 55% methane(CH4), 35% carbon dioxide (CO2), some nitrogen(N2) and a number of other gases in small amounts.Emissions of methane are a substantial contributorto the total emissions of green house gases (GHG).It is estimated that emissions of methane fromlandfill sites in the OECD countries contribute toaround 3 % of total GHG emissions.


Appendix 1

Kiyoshi Okamoto/IDI

An efficient system for storage and collection ofwaste is the key to preventing risks to human he-alth, environmental problems and other nuisances.There is a strong interrelationship between the typeof waste container used and the collection andtransport system that ought to be used. Collectionand transport is normally the most expensive part ofa waste management system and typically repre-sents two-thirds of the total cost in most countries.Lack of technical and financial resources in develo-ping countries often leads to insufficient use of stor-age bins and low collection frequency, if there is anyorganised waste collection at all.

Most countries require that hazardous waste is hand-led separately from non-hazardous waste, and forthis reason some additional information on the hand-ling of hazardous waste is presented in section 4.3.

4.1 Storage before collectionTo reduce problems such as vectors, rodents, scat-tering of waste, etc. connected to the storage ofwaste before it is collected, containers or binsshould be used. As far as possible these should be:

• Weatherproof, water tight and with a lid• Animal and insect proof• Washable and robust enough for daily use• Easy to handle and transport, and compatible

with the collection vehicle used

The type of storage container used depends on therate of waste generation (family size, etc.), type ofwaste to be collected, frequency and system of col-lection, and ability to pay.

The use of temporary containers such as cardboardboxes, plastic bags, etc. is common in low-incomecountries. They do not normally meet the require-ments listed above and therefore create problems.More permanent containers like plastic bins, oildrums, etc. reduce the environmental problems butare more costly.

Fixed storage points such as depots – masonry enc-losures (covered/uncovered) where people bringtheir waste from their home and where it is stored

before it is collected – are commonly used in develo-ping countries. This system creates environmentalproblems as well as resulting in unhealthy and time-consuming collection. Portable bins/containersranging from 0.2 to 30 m3, which are loaded mecha-nically directly onto the vehicle, create fewer pro-blems but require specialised vehicles and are the-refore more expensive.

4.2 Collection and transportThis includes all steps from storage to final treat-ment or disposal and involves labour and vehicles.Since this is the most expensive part of a waste ma-nagement system, it is important to undertake aproper evaluation of possible collection systems ba-sed on calculations and time studies before deci-ding which system to use.

The following factors must be taken into considera-tion: type of waste (categories, characteristics(high/low density), generation rate), climate, popula-tion density, roads and traffic conditions/accessibi-lity, type of storage containers used, vehicles (avai-lability, spare parts, maintenance costs, fuel costand consumption, load capacity, etc.), final treat-ment (type and distance from collection area), la-bour cost, willingness and ability to pay.

Waste collection can be carried out in differentways, such as:

• Communal collection, where the waste generatorbrings his waste to a dedicated collection point.

• Block collection, i.e. residents bring their wasteto the vehicle, usually at a signal from the vehi-cle.

• Door-to-door collection, which means that thecollector visits the premises and brings thewaste to the vehicle.

A combined system, whereby a primary collectionsystem brings the waste to a transfer station wheresome sorting and/or treatment can take place be-fore it is transferred to other vehicles that transportthe waste to the final disposal site, has proven it-self to be a rational and affordable system in manyplaces. There are two main reasons for doing this:

4 Storage, collection and transport


Appendix 1

to increase the efficiency of costly trucks and to es-tablish an acceptable system for waste collectionwhere accessibility is bad. A third reason is that thedistance from the collection area to the final dispo-sal site can be long and the vehicle used for collec-tion might be unsuitable for long-distance transport(for instance, because the load capacity is toosmall, the speed is too slow, the road conditionsare bad, or it is impossible to transport waste byroad). This normally means either using largertrucks or containers that can be transported byroad, railway or boat to the final disposal site.

The distance from the initial collection area to the fi-nal disposal site must normally be more than ap-prox. 40 km before it is economical to establish atransfer station. However, this has to be calculatedindividually for each case, since local conditions canvary greatly.

4.3 Special precautions for hazardouswasteBecause of the special properties of hazardouswaste, special precautions must be taken duringcollection, transport and storage, both before andafter transportation.

Several systems exist for collection and transporta-tion of hazardous waste, and it may be that some ofthe points below do not apply in all cases. Large ge-nerators, such as the chemical industry, will someti-mes transport their waste directly to the destructionplant, while small businesses can bring their wasteto intermediate stores or have it collected by an aut-horised collector. Similar systems also exist for ha-zardous waste from households.

An increasing trend is that specific systems are im-plemented for specific types of waste. This is alsoreferred to as Producer Responsibility. For instanceelectric/electronic devices with hazardous compo-nents can be returned to the producer or to theshop that once sold them.

Storage before collection

Before collection, precautions must be taken to en-sure that hazardous waste is not allowed to comeinto contact with other waste (hazardous or non-ha-zardous), does not lead to pollution, and is notmade available to children or unauthorised person-nel. This can be achieved through storage in tightcontainers, in locked rooms or behind fencing.

Hazardous waste is not only generated by industry.In households, hazardous waste such as lead acidbatteries, insecticides and detergents can causeharm to children and animals if not stored properly.

Collection

At the collection point, it is absolutely necessary todetermine the type of waste and its hazardous pro-perties to avoid damage to personnel and equipment.In addition to being dangerous on their own, many ty-pes of waste can react vigorously with each other andit is important to keep these away from each other.All packaging should be inspected, making sure thatit is clearly labelled according to local and internatio-nal laws, free from spill and tightly capped.Waste removal by horse. Arne Strømme / Samfoto


Transportation

Most types of hazardous waste are also dangerousgoods and should be transported in accordance withthe UN Recommendations on the Transport ofDangerous Goods. The Convention, in combinationwith local laws, regulates among others:

• Training of driver and co-driver• Types of packaging to be used• Labelling and marking of packaging and vehicle• Equipment on the vehicle (absorbent, stop

blocks, fire extinguisher, flash light, etc.)

Storage before treatment

Finally, storage of hazardous waste awaiting treat-ment requires more from the facilities than storageof non-hazardous waste. Here are some points toconsider when establishing storage for hazardouswaste:

• The storage point should be located a safe dis-tance from residential areas

• Incoming waste must be inspected before it canbe stored

• All waste should be stored under a roof, protec-ted from rain and wind

• The floor should be made of asphalt or concrete,to avoid pollution of soil and groundwater

• In the event of spills, absorbents and spare pack-aging material should be available

• Only authorised personnel should have accessto the storage facilities

• Protective clothes and first-aid kits must be avai-lable, as well as emergency showers

• A log should be kept, listing types and quantitiesof waste in the store at any time

• The local fire department should be notified ofthe storage and should be invited to inspect it


Appendix 1

Tore Wuttudal / N

N / Sam

foto

Knowledge of the characteristics of the waste andproper monitoring of the waste quantities being ge-nerated are important in order to choose the bestway to approach waste handling. This chapter des-cribes various ways of treating waste, depending onthe composition of the waste.

5.1 GeneralA list of priorities (the waste hierarchy), which hasbeen adopted in most countries, is shown in Figure3. Pyramids are often used to describe the goals fora process; the higher up the pyramid you are, thecloser you have come to your goal. The three R’s(Reduce, Reuse and Recover) of waste managementcover the upper three stages of the pyramid andshould be the goals for handling of waste.

However, the economic situation in the region willoften decide what actually happens to the waste. Inmany countries, the price of landfilling (or leavingthe waste at open dumps) is low compared with thecost of implementing the three R’s. This results inlandfills and dumps being the most common solu-tion. Thus, even if open dumps are the least desira-ble solution, this is actually the most commonlyused method of waste disposal in many countries.

Since a treatment plant is also a potential source ofpollution, most countries have legislation that ma-kes it illegal to establish a new waste processing ortreatment facility without a permit. Normally, the per-mit will include requirements on how to operate theplant. The European Union, for instance, has issueda number of directives that the member states andassociated member states have to observe, whichinclude minimum standards for permissions to esta-blish an incineration plant or a new landfill. Suchsystems are implemented in most industrialisedcountries but are absent or not being implementedin many developing countries.

5.2 Recovery (recycle and reuse)Recovery is a term that covers many aspects of utili-sing the material and energy resources of waste.Recovery can be subdivided into:

Material recovery:• Reuse (beverage bottles are reused for beverages) • Recycling (bottles are melted down, compost

is produced, etc.)

Energy recovery:• Incineration (production of hot water, steam

or electricity)• Use directly as a fuel• Gasification (produce gas that can be used

to produce hot water, steam or electricity)

There are several good reasons for recovering asmuch of the waste as possible: this reduces theamount of waste sent for final disposal and therebyreduces transportation and disposal costs, it makesuse of valuable resources in the waste and therebyreduces the use of virgin raw materials, and wastehandlers can earn money from the sale of recove-red/recycled materials.

When considering how to recover waste, it is impor-tant to know:

• The composition of the waste (percentage of paper, plastics, glass, etc.)

• The physical characteristics of the waste (den-sity, moisture content, size distribution, etc.)

5 Approaches to waste handling


Dispose (Controlled)

Treat and Process

Recover Materials(Recycle & Reuse)

Minimise

Avoid

Open uncontrolled dump

Des

irabi

lity

Figure 3: The waste hierarchy

Appendix 1


• The labour costs and market situation for recove-red fractions (cash value locally, export valueand possibilities, etc.)

• The requirements on cleanness of waste to berecycled

• The alternative treatment costs for unsortedwaste

The waste that is to be recovered can either be col-lected source separated (paper, glass, food waste,etc. in separate containers) or mixed in one contai-ner. When it is collected mixed, it can be difficultand costly to separate it for material recovery.Separation can be done manually or mechanically.Manual sorting of mixed waste can cause healthand safety problems for the workers, but is usuallythe cheapest and best way to achieve a clean pro-duct. For this reason, it is commonly used where la-bour is cheap. Mechanical separation, however, sel-dom gives a clean enough product for material re-use and can be capital intensive and costly tooperate.

5.3 Composting – treat and processTo be able to exploit the assets in waste (as a ma-terial or energy resource), the waste normally has tobe treated and/or processed. One way of treatingand processing is composting.

Composting means decomposition by living micro-organisms of the biodegradable solid waste (organiccompounds) under aerobic (with oxygen) conditions.Composting is the most common way of treating sewage sludge, park and garden waste and foodwaste. As seen in section 2.6, the organic compo-nents often make up the bulk of household waste,especially in low-income countries, and treating thisas a separate fraction by composting has many be-nefits. It increases diversion of waste from final dis-posal and thus reduces disposal costs, it enhancesrecycling operations (included incineration) by remo-ving organic matter from the waste stream, and itproduces a valuable soil amendment (which repre-sents a potential income). Furthermore, it is flexiblefor implementation at different levels (small-scale;each household, decentralised; at community level,

Ove Bergersen / N

N / Sam

foto

and large centralised plants), it can be done at a re-latively low capital and operation cost, and it can bea way to avoid negative health effects resulting fromorganic waste (i.e. dengue fever).

However, there are also some disadvantages thatwe must be aware of. Attention to and knowledge ofthe biological processes and their requirements areabsolutely necessary. Successful composting is de-pendant on parameters such as: sufficient oxygen,correct moisture content (50-60%), correct contentof nutrients for the micro-organisms to work, suffici-ent micro-organisms, temperature (ideally between55 and 65 ˚C and below 75 ˚C), pH in the range 6-8,porosity, structure, texture and particle size, curingand final conditioning. There is a nuisance potential(odour, insects and rats) if the composting processis not managed properly. And finally, there is often alack of vision and marketing plans for the final com-post product. Such plans are crucial to make com-posting a good alternative. Establishing the need forcompost in the market and the possible price forthe compost is essential.

It is also important to know that a composting plantcan only treat a portion of the waste stream and hasto be supplemented with other treatment facilities.

5.4 Energy from waste – treat and processAs described in section 2.6, waste contains variousamounts of combustible fractions such as organicmatter, paper/cardboard, plastics, etc. Some fracti-

ons, such as waste oil and organic solvents, can beused directly as a replacement for other fuels. It isdesirable that as many as possible of these compo-nents be recycled and used to produce new or simi-lar materials. However, the market value and recy-cling possibilities vary and there is an economic li-mit to how much of the waste it is feasible torecover. The residuals can then be utilised forenergy production. How this is done is dependenton a number of factors, including moisture content.If the moisture content is low (< 55-60%) it can beincinerated. If it is higher it can be used for biogasi-fication and the gas produced used for energy pro-duction.

Incineration (all types of waste)

Controlled incineration of waste in dedicated plantsmust not be confused with the uncontrolled burningof waste that takes place in open dumps, in privatehomes, on streets, etc.

Incineration has been a common treatment processfor decades in many industrialised countries, mainlyas a way to break down waste. Little or no interestwas paid in earlier days as to the adverse environ-mental emissions the incineration led to. Old incine-rators were a major source of emissions of dioxinsand heavy metals. In later years, however, the tech-nology has been refined and more attention hasbeen paid to reducing the emissions. Strict regulati-ons now have to be met when establishing a new in-cineration plant. Recovery of energy has now alsobecome a main reason for establishing incinerationplants.


Illustration 1. Incinerator. Source: MARTIN GmbH für Umwelt und Energieteknik.

Appendix 1

The advantages of controlled incineration are:

• It is an efficient way to reduce waste volume andthereby the need for landfill space

• Energy recovery (as heat and/or electricity) fromwaste, which can be regarded as a renewableenergy source, can replace the use of fossil fuelsuch as oil or coal

• The climate emissions from alternative treat-ment methods such as landfilling will be reduced

However, there are also some disadvantages to incineration:

• It involves heavy investments and high operatio-nal costs

• It is a technically complicated process that requi-res skilled personnel

• It is best suited for waste high in energy and lowin moisture and it must be supplemented withother methods since it can treat only a portion ofthe waste

• If not done properly, incineration can be a majorsource of pollution

These disadvantages mean that incineration ofwaste is a totally inappropriate option in most deve-loping countries.

Use of waste as a fuel substitute (hazardous waste)

Some types of hazardous waste, such as waste oiland organic solvents have a high-energy content,and can in many cases replace other types of fuel.The difference between incineration and use as afuel is that incineration is done in a specially con-structed plant. When used as a fuel, however, thewaste directly replaces other types of fuel in an exis-ting furnace or kiln.

The most common case is burning waste oil in a fur-nace or cement kiln originally designed to burn hea-ting oil. With a little adjustment, most furnaces andkilns can be converted for burning waste oil. Inmany cases, waste oil is cheaper than heat oil whilehaving almost the same energy content. This crea-tes a market for waste oil as an energy source.

The problem with waste oil is that it is contaminatedwith both heavy metals and organic substances thatare hazardous to the environment. For this reason,waste oil is classified as hazardous waste in mostcountries, and normally tighter control is applied onthe people that handle it. Most of the organic com-ponents will be destroyed when the oil is burned,but the remainder, along with the heavy metals will

leave the furnace along with the exhaust gases andpollute the environment. To cope with this problem,many countries require that only plants with a per-mit and sufficient filtering of the exhaust gases beallowed to burn waste oil.

Gasification (organic, non-hazardous waste)

Another way to treat biodegradable solid waste (or-ganic compounds) and also night soil, manure andsewage sludge is to establish a digester. A digesterthat operates anaerobically (without oxygen) can beused to produce methane gas. Since methane gashas a high energy content, it can be used to pro-duce energy like hot water, steam and electricity.

A digester can be built in many ways, and it can bemore or less advanced. It can be operated as asmall-scale facility or a large-scale facility. However,it requires more investments than composting andis a little more complicated to operate than a com-posting plant. Two reasons for establishing a diges-ter rather than composting the waste are a need forenergy and a lack of market for compost as a pro-duct.

Gasification, like composting, is a treatment methodthat can only utilise a portion of the waste and the-refore has to be supplemented with other treatmentfacilities.

5.5 Treatment of hazardous wasteTo reduce or eliminate the hazardous properties ofwaste, different alternatives can be used. The twomain approaches are thermal destruction and che-mical treatment, which is often used on inorganichazardous waste. There are a large number of tech-niques available, but the most common ones areneutralisation and stabilisation.

Thermal destruction

For many types of waste, especially organic hazar-dous waste, it is impossible to recycle or reuse thewaste, leaving us with no choice but to have it de-stroyed. There can be many reasons for this. Someexamples are PCB (banned in most countries), mix-tures that are impossible to separate and reuse(e.g. combinations of paints and solvents) or thereis simply no use for the waste. Being organic, thewaste can be converted into harmless componentssuch as carbon dioxide and water as long as thetemperature is high enough. Because halogenssuch as chlorine and bromine are very stronglybound to the carbon atoms, tearing the bindingsapart requires a supply of external energy. Energy isusually supplied by mixing the energy-consuming


waste with energy-yielding waste, and burning themixture either in a designated destruction plant or ina plant where the excess energy can be utilised,e.g. in a cement kiln. To have a proper destructionof for instance halogenated compounds, a tempera-ture above 1100 degrees C is required.

Neutralisation

This type of technique is most commonly used oncorrosives, such as acids and alkalis. When mixedin the right proportions acids and alkalis neutraliseeach other, and the products of this process are of-ten relatively harmless. Precipitates from the pro-cess can often be landfilled on a site for non-hazar-dous waste, while liquids from the process can beled to a recipient. Depending on the original waste,it may be necessary to remove hazardous compo-nents from the liquid.

Physical stabilisationSome types of inorganic hazardous waste can betreated by a process called stabilisation. In short,the process seeks to immobilise the hazardouscomponents by "locking them in place", usually bymixing the waste with gypsum, concrete or evenmolten glass and casting it into blocks. After com-pletion, the mobility of the hazardous components isreduced to a level where the blocks can be landfilledat an acceptable risk.

Miscellaneous

In addition, there are a number of highly specialisedtechniques for various types of hazardous waste. Twoexamples are destruction of cyanides through oxidisa-tion with sodium hypochlorite and stabilisation of mercury by converting it to a sulphide (HgS) which isinsoluble in water and chemically very stable.

5.6 LandfillingEarlier in this chapter, we described different waysof recovering, processing and treating waste. Thesemethods are designed to handle only specific typesof waste and therefore have to be complementedwith other methods, normally a landfill, to be able totake care of the disposal of the total waste stream.

Sludge is what is left after water has been drainedfrom fluid or pumpable waste. Sewage sludge is theresult of draining water from sewage. In low-income/developing countries, sludge is often pumped intocanals/rivers or brought to a landfill/dumpsite,while most industrialised countries have built dedi-cated treatment plants. Depending on the industrialprocess, sludge from industry is often characterisedas hazardous waste.

LandfillsLandfilling is the most common solution for handlingeither all the waste or the residuals that cannot betreated as a part of other waste processing met-hods, such as composting, incineration, etc. There isa wide range of landfills that vary from open dumpsthat create adverse environmental problems to bothsoil, water and air to sanitary landfills that are a fullyacceptable environmental solution. Landfills are usu-ally divided into three different categories:

• Sanitary landfill• Controlled dump• Open uncontrolled dump

The main differences are the way they are operatedand the level of adverse environmental effects theyhave.

Environmental impacts of landfills

A landfill can have a number of environmental im-pacts. Contaminated water called leachate (waterthat has been contaminated by seeping through thewaste) can contaminate soil as well as ground waterand surface water. Emission of landfill gas normallyconsists of approx. 50 % methane, which has agreen house gas effect 21 times stronger than CO2.Uncontrolled fires and toxic emissions are quitecommon if the landfill is poorly managed and are amajor source of pollution. Furthermore, landfills of-ten cause littering problems, poor aesthetics, odour,rodents, insects, traffic and noise.

There are a variety of different actions that can be ta-ken to prevent the negative impacts mentionedabove. This can be daily/regular covering of the waste(this will reduce many problems like odour, littering,extensive uncontrolled fires, vectors, etc.), collection(and preferably purification) of the leachate, preven-ting water from entering the landfill and seepingthrough the waste (reduced amount of leachate), andextraction of landfill gas and preferably conversioninto effective energy since the methane has a highenergy content (it can be used to produce electricity,hot water, etc.). Setting up gates and fences aroundthe landfill will prevent unauthorised people and ani-mals from entering the area. Strict monitoring of thekind of waste being received is also precautionary.

5.7 CostsThe more that is done to reduce adverse environ-mental impacts, the more expensive it will be to es-tablish and operate all treatment plants, includinglandfills. Unfortunately, there is neither the will northe financial ability to pay adequate attention to the


Appendix 1

environmental problems that dumps create in manycountries. Therefore the least desirable alternativefor treatment of waste is actually the most com-monly used method in many countries.

There is a strong relationship between the capacityof a landfill and the cost in price per tonne. This cor-relation can be seen in Figure 4.

The cost of different waste processing and treat-ment alternatives varies widely. The cost is one im-portant parameter that will affect what alternative itis realistic to choose.

Table 4 shows how prices can vary between diffe-rent alternatives.

As seen in Table 4, crude dumping is very cheap. Aslong as this is accepted, it is hard to climb the pyra-mid seen in figure 3 (page 81). Strict environmentalregulation (which makes dumps prohibited) is there-fore needed as an instrument to improve overallwaste management. An economic instrument that isimplemented in many Western countries is a wastetax on all waste being landfilled. This increases thecost of landfills and thereby makes it more profita-ble to recover and process the waste instead of lea-ving it all to a landfill.


Technique US $/tonne

Crude dumping 1 – 3

Sanitary landfill 6 – 12

Sanitary landfill, reclamation area 12 – 24

Composting at landfill 30 – 60

Biogasification 60 – 100

Incineration 30 – 120

Table 4: Typical cost of different treatment methods. (Source: ADB/NORAD project Phnom Penh, Cambodia 2002).

High income

Medium income

Low income

$/tonne

Tonnes/day

Figure 4: Correlation between capacity and cost

Waste management is an important part of moderninfrastructure as it ensures the protection of the en-vironment and of human health. It is not only a tech-nical and environmental issue but also a highly poli-tical one. Waste management is closely related to anumber of issues such as urban lifestyles, resourceconsumption patterns, employment and income le-vels, and other socio-economic and cultural factors.

A vast majority of countries, especially developingcountries, are still struggling with such basic issuesas ensuring sufficient collection services and imple-menting a minimum degree of control at disposal si-tes at the same time as they are facing increasingquantities of waste and a change in waste composi-tion due to increasing urbanisation. They also lackthe technical and financial resources to safely ma-nage solid waste – which includes adequate provisi-ons for storing the waste at the point of generation,efficient and sufficient collection services as well assatisfactory final disposal.

It is important to be aware of the fact that improperwaste management may cause adverse health pro-blems by spreading infections and diseases andmay cause severe environmental problems by pollu-ting the air and the soil, surface water and ground-water.

Lack of proper waste collection and dumping ofwaste at uncontrolled dumps often leads to uncon-trolled burning of waste dumped along streets or atdumpsites to destroy the waste and to "get rid ofthe problem". The result is incomplete combustion,which results in toxic and carcinogenic emissions ofPAH (polyaromatic hydrocarbons), dioxins, etc. Thishabit of waste disposal is one of the major sourcesof emissions that are harmful to human health andthe environment.

Reducing the amount of waste being generated andreusing and recovering as much as possible of thewaste are important general goals that will help re-duce the problems the waste generates. Hazardouswaste should be collected and treated separately. Acontrolled landfill, where open burning of waste isbanned and where polluted water and gases can betaken care of is normally the best solution for trea-ting the fractions of waste that are not suited for re-covery. Sending waste to energy plants is normally atreatment method that is more readily applicable inhigh-income countries.

6 Summary


Appendix 1

Tanker loaded with oil. Tore Wuttudal / NN / Samfoto

H1 ExplosiveSubstances and preparations that may explode under theeffect of flame, or are more sensitive to shocks or frictionthan dinitrobenzene.

H2 OxidizingSubstances and preparations that exhibit highly exother-mic reactions when in contact with other substances, par-ticularly flammable substances.

H3-A Highly flammableLiquid substances and preparations that have a flashpoint below 21 °C (including extremely flammable liquids): substances and preparations that may become hot and fi-nally catch fire in contact with air at ambient temperaturewithout any application of energy; solid substances andpreparations that may readily catch fire after brief contactwith a source of ignition and that continue to burn or to beconsumed after removal of the source of ignition; gaseoussubstances and preparations that are flammable in air atnormal pressure; substances and preparations that, incontact with water or damp air, evolve highly flammablegases in dangerous quantities.

H3-B FlammableLiquid substances and preparations that have a flashpoint equal to or greater than 21 °C and less than orequal to 55 °C.

H4 IrritantNon-corrosive substances and preparations that, throughimmediate, prolonged or repeated contact with the skin ormucous membrane, can cause inflammation.

H5 HarmfulSubstances and preparations that, if inhaled or ingestedor if they penetrate the skin, may involve limited healthrisks.

H6 ToxicSubstances and preparations (including very toxic sub-stances and preparations) that, if they are inhaled or inge-sted or if they penetrate the skin, may involve serious,acute or chronic health risks and even death.

H7 CarcinogenicSubstances and preparations that, if they are inhaled oringested or if they penetrate the skin, may induce canceror increase its incidence.

H8 CorrosiveSubstances and preparations, that may destroy living tis-sue on contacts.

H9 InfectiousSubstances containing viable microorganisms or their toxins, which are known or reliably believed to cause dis-ease in man or other living organisms.

H10 TeratogenicSubstances and preparations that, if they are inhaled or ingested or if they penetrate the skin, may induce non-hereditary congenital malformations or increase their inci-dence.

H11 MutagenicSubstances and preparations that, if they are inhaled oringested or if they penetrate the skin, may induce heredi-tary genetic defects or increase their incidence.

H12 Substances and preparations that release toxic or very toxic gases in contact with water, air or an acid.

H13 Substances and preparations that are capable by any me-ans, after disposal, of yielding another substance, e.g. aleachate, which possesses any of the characteristics li-sted above.

H14 EcotoxicSubstances and preparations, that present or may pre-sent immediate or delayed risks for one or more sectorsof the environment.


6 Taken from council directive of 12 December 1991 on hazardous waste (91/689/eec) The council of the European communities.

Properties of wastes which render them hazardous6

Appendix 1


Norwegian Radioactive Waste Management SystemAppendix 2:


: Canadian Radioactive Waste Management SystemAppendix 3:


Canadian Hazardous Waste Management SystemAppendix 4:


Canadian Non-hazardous Waste Management SystemAppendix 5:


Chinese Waste Management System, excluding Radioactive Waste

Appendix 6:


Appendix 6


Norwegian Hazardous and Non-hazardous Waste Management

Appendix 7:


Polish National Waste Management SystemAppendix 8:

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