UNIVERSITY OF MALTA Junior College · Malta produces about 1.6 million tonnes of solid waste per...

UNIVERSITY OF MALTA

Junior College

Vince Sammut

Prepared by Vince Sammut 2

Table of Contents

Table of Contents _____________________________________________________________ 2

List of Tables_________________________________________________________________ 2

List of Charts ________________________________________________________________ 2

Executive Summary____________________________________________________________ 3

Introduction: Waste generation in Malta ___________________________________________ 4

Sustainable waste management __________________________________________________ 6

Maltese legislation ___________________________________________________________ 10

Waste recovery costs vs. disposal costs. ___________________________________________ 13

Bibliography ________________________________________________________________ 21

List of Tables

Table 1: Non-hazardous mineral waste disposed in disused quarry sites.....................................5

Table 2: Waste disposed in public landfills ....................................................................................6

Table 3: Waste treated at Sant' Antnin Waste Treatment Plant ...................................................12

Table 4: Separate collection of waste materials..........................................................................................13

List of Charts

Chart 1: Waste (except debris material) disposed in public landfills: 2000-2006____________ 6

Chart 2: EU Waste related Directives _____________________________________________ 9

Chart 3: Centre for the Selective Collection of Special Waste__________________________ 11

Chart 4: Composition of waste treated in Sant' Antnin Waste Treatment Plant (2000-2006) __ 12

Chart 5: Waste collected from bring-in sites: 2003-2006 _____________________________ 13

Chart 6: Projection of overall Waste Management Cost in the EU _____________________ 14


Executive Summary Applying a holistic and integrated waste management policy implies the adoption by society at large of the concepts of: prevention, selective collection and maximum re-use of waste, Reducing waste generation to a minimum is essential on an island as small and as densely populated as Malta, for two reasons:

1. to prevent further expansion of a large chunk of the island from becoming an even more aesthetically repulsive and hazardous rubbish dump and,

2. to reduce or eliminate unnecessary economic and social costs, costs which may already be jeopardising our future as a tourist destination.

Basing a waste policy on prevention, separation at source and recovery and reuse is a key factor for achieving high re-cycling levels. But this requires public co-operation and participation. And this, in an island where insularity has embedded a tradition of diehard conservatism and a sense of ego-centrism, where every rule and regulation is there to be broken and openly flouted, is in itself no easy task. It implies a cultural change. But other countries including small islands, such as the Canary Islands have successfully embarked, albeit with help from external sources, on a road leading to economic sustainability.

Like other small island States, Malta tends to look at its bigger industrialised neighbours for help and guidance. The principles of sustainable waste management as practiced by European States therefore provide a good, although by no means perfect, basis on which it can set its environmental practices. Current EU policy on Waste Management strongly promotes the principle of producer responsibility and gives precedence to the recovery of materials over energy generation.

The overall structure of the EU’s waste management regime is set out in the Waste Framework Directive (Directive 2006/12/EC) and its complementary Hazardous Waste Directive (Council Directive 91/689/EEC). These Directives along with a host of other specific directives and regulations underpin the principles of:

� waste prevention, � recovery and, � minimisation of final disposal.

The need to adopt and implement these principles is nowhere better felt than in the Maltese building and construction industry; an industry where productive and allocative inefficiencies are so rampart that 84.4% of waste dumped at Maghtab are construction and demolition wastes.

Economic instruments and productive methods based on the 3Rs principle are the means by which externalities can be taken into account and scarce mineral and land resources efficiently allocated.

Investment in projects such as land reclamation, state-of-the-art engineered landfills, municipal solid waste incinerators (with or without energy recovery) and ultra-modern technologies such as Plasma Waste Converter Systems, has to be carefully planned in a holistic and integrated manner. Clearly defined objectives, feasible plans and a well-informed and educated population; coupled with modern technology as well as foreign technical and financial aid, are the surest roads towards sustainable waste management.


Introduction: Waste generation in Malta

Waste management, in small island states lacking natural and financial resources, is a serious obstacle for sustainable development. Attaining socio-economic growth without jeopardising the needs of future generations is undoubtedly the main environmental problem that islands face. In Malta’s case, this is as yet, not fully recognised by society in general.

Malta is in the process of moving away from the land fill option for waste disposal, towards the more sustainable options on the waste hierarchy as deemed necessary by the European Union’s Waste Management Strategy (EU Policy document 1989).

Apart from the European Commission, the Maltese public too is becoming consciously aware of the gravity of the waste management problems. Yet, one thing that is often overlooked by the ‘man on the street’ as he routinely dumps away his daily garbage bag is the fact that the concept of waste is not an irrevocable natural phenomenon. Waste is after all a human invention! In nature all matter is recyclable. But in contrast with nature, man's activities result in the production of discarded by-products, the constituents of which are identical to the natural resources that are extracted from nature, imported, manufactured, or otherwise traded. And this we call “waste”.

Indeed, Council Directive 75/442/EEC (Art.1(a)). - The Waste Framework Directive - defines “waste” as:

“any substance or object … which the holder discards or intends or is required to discard”

Limestone, food, paper, glass, plastic, wood, metals, chemicals, and a host of other scarce resources make up our so-called wastes and this material is, for various reasons, not returned to the production cycle, but ends up in landfills where most of it remains. This results in the squandering of material resources, and in energy resources too, since the energy consumed in the production of a product is wasted as well. Adding insult to injury, man tries to compensate for this allocative and productive inefficiency by extracting and depleting even more material and energy resources. This further exasperates the waste problem and jeoperdises the ability of future generations to promote their own economic, social and environmental well-being.

This is ‘unsustainability’ at its best! And, as an example, one should look no further than Maghtab. The ‘Maghtab’ dump was until recently an ever-growing aesthetically repulsive eyesore of a mountain, erroneously called a ‘landfill’; an evident manifestation of the gravity of Malta’s waste management problems. Dominating the island’s northwest landscape, ‘Maghtab’ is still considered by many environmentalists as a health hazard:

‘As it stands, this mountain of waste is a toxic time bomb…The site is contaminated by a cocktail of toxic chemicals…It is obvious from the initial samples taken, that Maghtab is an extremely contaminated site.’

Greenpeace Report: ‘No Time To Waste’ April 2000

Health implications and aesthetics apart, one cannot ignore the odour, flies and vermin that the dump generates. Neither can one ignore spontaneous fires or explosions and emissions of methane and carbon dioxide, two ‘green house’ gases. Traffic congestion and road related problems are also an issue. Given its geographic location, ‘Maghtab’ may not be a serious threat in terms of contaminating the water table with toxin leachate. But it may contaminate the offshore sea and this would doubtlessly have negative impacts not only on the scarce


recreational facilities of the general public but also on tourism, one of Malta’s major foreign exchange earners and GDP generators.

Malta produces about 1.6 million tonnes of solid waste per year, an average per capita output of 4 tonnes per annum. Over the years, as the country’s standard of living increased, the biodegradable fraction of waste decreased while the range and amount of hazardous chemicals used in industry and in households also increased. Municipal waste accounts to 7.3% of the total, while industrial waste accounts to 8.3%. Construction and demolition waste makes up the rest, an astronomical 84.5%. The year 2004 saw the highest amount of waste recorded, when 2,874,853.56 tonnes were sent to treatment and disposal sites.

Table 1: Non-hazardous mineral waste disposed in disused quarry sites

Out of about 1.4 million tons of solid waste that were disposed of at Maghtab and Sant` Antnin in the year 2000, 1.17 million tons were construction waste, 165,000 tons were domestic waste and 88,000 tons were industrial waste, an estimated increase of 18 per cent over 1999. Construction waste alone was up by 230,000 tons or 25 per cent. This translates into over 750,000 cubic meters per year, enough to cover the whole Maltese islands with over half a meter of construction waste in just 75 years! (Prof. L. Briguglio et al.).

The unrestricted production of waste, with government or local councils carting away and dumping it - at a huge public expense1 - in some remote location; if anywhere can be considered as ‘remote’ on a small island of 316 sq. km with a population density of over 1,200 souls per sq. km, is clearly an unsustainable option. And as the country’s economic growth and standard of living continue to accelerate on a forward tack, so will the landfill problem. Indeed, projections for Malta - assuming waste minimisation initiatives - envisage a 34 per cent increase in municipal waste and a 60 per cent increase in industrial waste for the years leading to 20092. Thus, not only is mere disposal unsustainable as a long-term option, but it is also a potential source of pollution and a risk to public health and the environment.

1 The costs incurred by Local Councils for the collection of solid municipal waste in 1999 ranged from Lm 2.16 per

inhabitant in Region 5 to Lm 4.49 in Region 1: A Solid Waste Management Plan For Malta – Ministry for the Environment, Appendix III. January 2000

2 Source: A Solid Waste Management Plan For Malta – Ministry for the Environment, Chapter 3


Till April 2003, all solid waste generated was disposed in the public landfills at Maghtab in Malta and il-Qortin in Gozo. However due to a change in waste disposal policy, the greater part of this waste began to be disposed in disused quarry sites from May 2003 onwards. Table 2 shows the details of the waste streams which were received at the public landfills. The non-hazardous mineral waste disposed in disused quarries follows a fluctuating trend, with the highest amount recorded in 2004, when over 2.5 million tonnes of mineral waste was disposed of in this manner.

Table 2: Waste disposed in public landfills

Chart 1: Waste (except debris material) disposed in public landfills: 2000-2006

Other contributions to waste creation, albeit in small quantities are ‘special wastes’. These come from the health care, catering and agricultural sectors of the economy. Sewage sludge, oil waste, copper and nickel grit, asbestos and batteries also make their way to the refuse dump.

“Indeed, anything from body parts to oil sludge is dumped at Maghtab.” Profs. Alfred Vella UOM

Health-care waste, if not properly handled, can be very hazardous. Not only are its components aesthetically offensive, but also more often than not, they are corrosive, genotoxic, radioactive, as well as potentially infective.

Sustainable waste management

As in many other areas of public administration in Malta, ‘management by crisis’ has for years been the ‘rule of thumb’. Moreover ‘end-of-pipe’ solutions for waste management are still the norm. Malta definitely needs to move up the ‘waste hierarchy’ and formulate more sustainable waste management policies that adopt stringent operational standards in waste facilities.


Like all small island developing States, Malta shares the problem of how to safely dispose of wastes, particularly the wastes generated by urbanisation. As stated in the Programme of Action for the Sustainable Development of Small Island States:

Point source pollution from industrial wastes and sewage inappropriately sited and poorly managed garbage dumps and the disposal of toxic chemicals, are significant contributors to marine pollution and coastal degradation. Limited land area makes the option of landfill disposal unsustainable in the long term. III (22) A/CONF.167/9, part I, Annex I (1994)

www.unep.ch/islands.htm

And like other small island States; Malta tends to look at its bigger industrialised neighbours3 for guidance. The principles of sustainable waste management as practiced by European States therefore provide a good, although by no means perfect, basis on which it can base its environmental practices.

Its various Environmental Action Programmes have for the large part determined EU Directives on waste. In 1989 the EU drew up a policy document entitled ‘Waste Management Strategy’ (SEC (89) 934, 18.09.89) which set long-term aspirations with regard to the European Union’s waste management legislation and activities. Its main principles were:

• Prevention of waste by technologies and products; • Recycling and reuse; • Optimisation of final disposal; • Regulation of transport; • Remedial action.

On 24 February 1997, the European Council adopted a Resolution on a Community strategy for waste management, which is a review of the 1989 strategy. This Resolution underpins the principles of waste prevention first, then recovery and finally, minimisation of final disposal. It also confirms the current EU policy on the movements of waste and gives precedence to the recovery of materials over energy generation and it strongly promotes the principle of producer responsibility.

The aim of European Union’s policy on the environment is to ensure sustainable development. Indeed, the Treaty of Amsterdam has made the principle of sustainable development and a high level of environmental protection the EU’s top priorities, that is:

“to promote economic and social progress and a high level of employment and to achieve balanced and sustainable development…”

Article 2, Treaty of Amsterdam 2nd October 1997

Integrating environmental policy into Community sectoral policies, the use of preventive action and the introduction of economic instruments4, such as the ‘polluter pays’ principle, form the

3 In the European Union as a whole over two billion tonnes of waste are produced each year of which approximately

30 million tonnes can be classified as hazardous. Some 50-60% of the overall solid waste stream is land filled, though the proportion of land filled waste varies substantially in individual Member States and ranges from under 30% in Holland and Luxembourg to virtually 100% in Ireland, Portugal and Greece.

4 An economic instrument may take the form of a tax forcing a party causing damage such as pollution to ‘compensate’ victims. This concept is what led to the adoption of the ‘polluter pays’ principle by the Organisation for Economic Co-operation and Development (OECD) countries in 1972. Some governments have also found other ways of approaching the same result. They have resorted to charges, fees, and tradable and marketable


basis of the EU’s approach to sustainable development. Environmental damage is seen as a priority to be rectified at source while responsibility for environmental protection is shared out amongst all member States.5

The overall structure for an effective waste management regime as envisioned by the EU, is set out in the Waste Framework Directive (Directive 2006/12/EC) and its complementary Hazardous Waste Directive (Council Directive 91/689/EEC). Directive 2996/12/EC consolidates and replaces Council Directive 75/442/EEC and its aim is to clarify and rationalise the legislation on waste but it does not change the content of the applicable rules.

Two types of ‘daughter’ directives have elaborated these directives:

� One group sets down requirements for the permitting and operations of waste disposal facilities.

� The other group deals with specific types of waste such as oils, packaging and batteries.

Council Directive 75/442/EEC was itself substantially revised and amended in 1991 to provide a legal framework for the avoidance, management and disposal of wastes as set out in the Commission's Waste Management Strategy (SEC (89) 934, 18.09.89).

In essence, the underlying objectives of EU strategy is to enhance the prevention or reduction of waste and its harmfulness, by encouraging the development of clean technologies, technical product improvements, and disposal techniques. It also encourages the recovery of waste and its use as a source of energy. It is in this light that the Waste Framework Directive (2006/12/EC) prohibits:

‘the abandonment, dumping or uncontrolled disposal of waste, and must promote waste prevention, recycling and processing for re-use of waste.’

Moreover, in order to meet the goal of making the European Community self-sufficient in waste disposal, Member States must – while taking account of the best available technology not involving excessive costs (BATNEC) - establish an integrated and adequate network of disposal installations in co-operation with other Member States. And, in accordance with the ‘polluter pays’ principle the costs of waste disposal must be borne by the holder or the previous holder of the waste.

‘The measures provide for cooperation between the Member States with a view to establishing an integrated and adequate network of disposal installations (taking account of the best available technologies) so as to enable the Community as a whole to become self-sufficient in waste disposal and the Member States to move towards that aim individually. This network should enable waste to be disposed of in one of the nearest appropriate installations, so as to guarantee a high level of environmental protection.’

permits. However, they have also recognized that similar results can be achieved by providing compensation for not using polluting substances or technologies. Subsidies, tax allowances, and grants have been used in this manner. Other policy makers have opted for a combination of the two approaches utilizing deposit/refund systems, distributive credits and fee rebates ‘ (Barbier, 1992 p2; Gale and Barg, 1995 p5; von Weizäcker, 1992 pp 14-21)

5 As much as two hundred legal instruments make up the Community acquis and these cover a wide large range of fields, including air and water pollution, the management of waste and chemical products, biotechnology, radiation protection and nature conservation. Member States are also required to ensure that an environmental impact assessment is carried out before granting authorisation for the carrying out of certain public or private projects.


Chart 2: EU Waste related Directives

Transport, Import & Export

Shipment of Waste

(EEC/259/93) (EC/1013/2006)

Special Wastes

Titanium Dioxide Waste (78/178/EEC)

Packaging Waste (94/62/EC)

Waste Oils

(75/439/EEC) PCBs & PCTs

(96/59/EC) Batteries

(91/86/EEC) Sewage Sludge

(86/278/EEC)

Processing and Disposal Facilities

Waste Incineration (2000/76/EC)

This incorporates:

1. Municipal Waste Inc.,

(89/429/EEC) (89/369/EEC)

2. Hazardous Waste Inc.,

(94/67/EEC)

Landfill Directive (99/31/EC)

Waste Framework

Waste Framework Directive (2006/12/EC)

Hazardous Waste Directive (91/689/EEC)


Maltese legislation

Prior to EU accession in 2004, there was little doubt in the eyes of the European Commission, that Malta had been making slow progress in bringing its legislation in line with the environmental acquis. While positively noting Malta’s ratification of the Basle Convention on the ‘Transboundary Movement of Hazardous Waste’, the European Commission minced no words when it reported that:

“Concerning waste, no legislative progress can be reported…Extensive legislative transposition is necessary in practically all areas of waste management legislation in order to comply with the Community acquis… The investments needed to implement the acquis in the different sectors are certainly of a large scale, in particular with regard to waste management, water quality, nature protection (habitat) and Industrial Pollution Control and Risk Management. This makes it particularly important for the Maltese Government to develop a plan for financing investments (directive specific) based on estimations of costs of alignment, a short-term priority in the Accession Partnership.”

EU Commission’s Regular Report (Chapter 22, Year 2000)

It was in this light that the Maltese government speedily enacted a new Environmental Protection Act, the provisions of which focus on the concept of environmental sustainability and provide a framework for the adoption of both European environmental legislation and of international commitments that Malta has undertaken in recent years.

In January 2000, the ‘Department of the Environment’ published ‘The Solid Waste Management Plan – Consultation Document’, and a month later the ‘Planning Authority’ published its ‘Waste Management Subject Plan’.

The European Commission itself commissioned a British company ‘Integrated Skills Ltd’ to draft a solid waste management strategy report for the Maltese islands. The report is expected to include a comprehensive integrated solid waste management strategy that focuses on the future management of solid wastes.6

The ultimate objective of any waste management plan, no matter who carries it out, is to establish the right mix of economically and financially feasible options, with targets and time-frames regarding how much waste can be realistically:

� Reduced, � Reused, � Recovered and � Disposed off.

It is universally accepted that prevention is the first option in a waste management system. It is at the top of the waste management hierarchy because what is not produced does not have to be disposed of. This is a concept established in all EU regulatory texts related to waste and its fundamental goal is to achieve a better use of resources.

The issue is how much waste can be prevented while still providing citizens with a sustainable level of economic development?

6 This report is also expected to tackle certain other wastes of a semi-solid or liquid nature because of their

relevance and the importance of achieving compliance with European standards.


For example, while aiming at reducing environmental impacts, DIRECTIVE 94/62/EC on Packaging7 focuses mainly on the quantitative aspects of prevention. But balancing out environmental impact reduction with the real or perceived 8 needs of consumers involves socio-economic ‘trade offs’. Moreover, it is only attainable by taking measures throughout the life cycle of products, from production to sale, from consumption to final disposal. In other words, prevention is both Quantitative (source reduction and recovery), and Qualitative (limitation of toxicity and the separation of hazardous from non hazardous waste).

From a cost viewpoint, the notion of comparative cost and affordability can only be achieved by evaluating both the existing system of waste disposal and other available options. In addition, to recover as much waste as is practicable and affordable, one needs to assess recycling and other recovery options within a totally integrated and holistic system.

An example of an urban solid waste management program based on Recuperation, Recycling and Reuse is that developed for the Canary Islands. Indeed, Centres for the Selective Collection of Special Waste ‘Puntos Limpios’ have already begun to cover virtually the whole population of these islands. These Centres receive pre-determined urban waste, which has previously been separated at source by the citizens9.

http://www.gobiernodecanarias.org/medioambiente/eng/calidad/ptoslimpios.html

Chart 3: Centre for the Selective Collection of Special Waste

7 Packaging is possibly the single most important component in allowing a wide range of goods and services to

move from their point of production to the ultimate user or consumer. 63% of the 850 bln ECU traded every year between Member States is in goods or services packaged before sale. Source: European Recovery and Recycling Association (ERRA) http://www.erra.be/

8 The importance of Marketing and the maximisation of satisfaction in a modern consumer oriented society cannot be ignored, hence the strength of the pro-packaging lobby.

9 Paper, cardboard, tetrabrik, glass, PVC, other plastics, metals (bed bases, white goods, etc.), fluorescence tubes,

paint, inert material from small domestic jobs, (a maximum of 250 kg per day per delivery), vegetable waste, cooking oil, refrigerators, motor oil, car batteries, single cell batteries, medicines, sprays and X-rays. Refrigerators and refrigeration apparatus are left in a covered area where the CFCs (gases which damage the ozone layer) are removed.


By implementing such a program, not only are prime material and energy saved – and this means a low impact on the environment – but economic benefits such as the generation of employment are also incurred. Moreover, given small islands’ lack of economies of scale and high shipment costs, such a comprehensive system for take-back, collection, recovery and recycling of recoverable waste may encourage the introduction of export initiatives.

On average the amount of waste treated at the Sant’Antnin Waste Treatment plant in the period 2000 -2006 merely constituted 1.74 per cent of all waste managed in Malta. Leaving out the mineral waste and debris material from the total amount of waste managed in Malta, the treated waste streams account for only 11.61 per cent of the waste managed in the country. The amount of waste treated also shows a fluctuating trend; however from 2002 onwards a steady increase in the amount of waste treated was recorded. In 2002 the amount of treated waste was just 5.88 per cent of the total amount of waste managed excluding debris material and mineral waste. By 2006 the corresponding figure had risen to 16.7 per cent. Chart 3 shows that 87 per cent of the treated waste stream at Sant’Antnin comes from the mixed municipal waste.

Table 3: Waste treated at Sant' Antnin Waste Treatment Plant

Chart 4: Composition of waste treated in Sant' Antnin Waste Treatment Plant (2000-2006)


Table 4 and chart 4 below, give an insight on the separate collection of various waste streams. In Malta, separate collection began to gain momentum with the introduction of bring-in sites in July 2003. The amount of waste collected from bring-in sites has been on the rise ever since the introduction so that from 2004 to 2006 the amount of waste collected in this manner increased by 2.34 times

Table 4: Separate collection of waste materials

Chart 5: Waste collected from bring-in sites: 2003-2006

Waste recovery costs vs. disposal costs.

It is clear that as available space for landfills in Malta rapidly diminishes and land prices rocket sky high, waste disposal costs via traditional routes are also rapidly increasing10. On the other hand, other options such as incineration and energy recovery require heavy capital investments and high operational costs.

But one has to keep in mind that in spite of high initial costs, the cost of diverting waste from final disposal would eventually start to compare favourably, in particular when the revenues from secondary materials and other ancillary benefits are included. Reduction, Reuse, Recovery and Recycling should be considered as part of an overall total waste management scenario that must be socially acceptable, economically and environmentally affordable, and thus sustainable. This means that costs have to be seen in relative and not in absolute terms. In relative terms, the cost of recovering a portion of the waste should be expected to fall, while the cost of traditional disposal should increase over time.

Indeed, it is possible that over time, the specific cost of recycling waste can and will decrease to a point where it becomes negligible or even a net contributor in comparison to other processes

10 These costs are in the main still considered as ‘externalities’, and are therefore unaccounted for in financial terms.


and other waste management costs. According to the European Recovery and Recycling Association (ERRA) http://www.erra.be/ and as illustrated in the block graph below:

“a carefully planned system that includes recycling and other forms of recovery, and is tailored to a specific location, is likely to have a lower overall cost compared to a system which only includes disposal” Recycling Costs Money – or does it? (ERRA Review Issue 3 – June 1997)

Chart 6: Projection of overall Waste Management Cost with and/or without Recovery in the EU

Speaking at the 7th Malta Industry environment Conference on "INTEGRATED SOLID WASTE MANAGEMENT STRATEGY”, Mr. Nicholas Crick, director of Integrated Skills Ltd. estimated Malta’s compliance costs in connection with the implementation of EU legislation on waste as ranging between Lm 18.70 to Lm 40.85 per tonne. Capital expenditure may be as low as Lm 17.5 million and as high as Lm 64.7 million11. These estimates were based on the following five possible waste management strategy options:

¤ composting and recycling; ¤ waste-to-energy and recycling; ¤ waste-to-energy with no recycling; ¤ composting plus recycling and waste-to-energy in 2013; and ¤ composting plus recycling, transfer from Gozo and waste-to-energy in 2015.

While these comparative costs may seem exuberantly high, it must be pointed out that internal factors, such as the efficiency of the system and external factors, such as disposal charges, will vary over time. Cost assessments must also include the perception of results achieved. Often, once a programme is up and running, it can be adjusted and optimised further as more operational experience is gained.

11 According to eight valid proposals tendered in to the government in respect of an Integrated Solid Waste

Management project, waste management costs range from Lm 3.5 m to Lm 139.5 m . Times of Malta 3rd April 2001.

Projection of overall Waste Management Cost with and/or without Recovery in the EU


In addition, once convenience and benefits are clearly perceived by local waste generators, their behaviour and participation would be positively affected. This therefore calls for a phased implementation of a waste management plan. By proceeding on a step-by-step basis, key experiences from a pilot scheme can be adapted and applied to a broader area as a programme develops.

It is ironic that one means of reducing landfill waste in Malta, was actually already in place prior to EU accession. Legal Notice 158 of 1998 provided that soft drinks could only be sold in refillable glass bottles or dispensed from a keg. This law aimed at reducing the amount of soft drink containers that are disposed in a landfill through the obligatory use of refillable glass containers. When one considers that a soft drink bottle may be used around 30 times before being disposed of, one can understand the environmental benefits of this law which had led to Malta having one of the most successful deposit-and-return schemes in Europe with a return rate of more than 90 per cent. Unfortunately the implementation of the EU’s Packaging & Packaging Waste Directive [DIRECTIVE 94/62/EC] no longer enforces the use of refillable glass bottles.

But the biggest hurdle of all is without doubt the Building and Construction Industry . A European Commission report drafted by the Construction and Demolition Waste Priority Waste Streams Project 12 (number 11) recommended that:

“Member States and their ‘competent authorities’ for waste management planning should consider the following options when assessing the measures necessary to improve the management of construction and demolition wastes. The measures adopted should avoid distorting the market and lead to demonstrable environmental benefit. The options available include, for example:

- selective restrictions or bans on the disposal of recoverable materials; - total bans on the disposal of certain materials; - the mono-landfill of certain materials for possible future recovery; - tightening environmental and planning controls on disposal; - the imposition of local, regional or national taxes or levies on the disposal of recoverable

materials.”

CONSTRUCTION AND DEMOLITION WASTE MANAGEMENT PRACTICES, AND THEIR ECONOMIC IMPACTS Report to DGXI, European Commission (Feb.!999)

This report highlighted the need that market forces should not be distorted. But the distortion of the Maltese mineral resource market is clearly evident to all and sundry. The high levels of inefficiency in the use of our land and mineral resources are, to put it mildly, incomprehensible. Huge basements and underground car parks are hewn out of good quality globigerina limestone and the rocks disposed of at Maghtab, with hardly any attempt of recycling the material. For example, enough material could have been quarried at the site of the new General Hospital, to build a town the size of Birkirkara! Even licensed quarries are so inefficient that two thirds of the material quarried is dumped.

12 The EU established in 1993 a programme to examine waste streams for particular products, notably health care

waste, demolition waste, used tyres, chlorinated solvents and end-of-life vehicles. Project groups were set up review each of these product areas and develop ways of dealing with them. Progress to date has been disappointing end-of-life vehicles pose problems because the Commission wants to exclude PVC in cars; demolition waste is of concern because of the enormous amount of waste generated; used tyres will be banned from landfill if Member States reach agreement.


Why? The reason is because, other than for the purchase price of land and the capital and labour costs incurred, operators consider everything else as an externality, and externalities bear no financial costs. More stringent waste management requirements and more efficient construction methods and practices such as selective demolition and recycling along with mono-landfilling13 should be introduced and implemented in order to mitigate the negative effects of waste generation.

While rehabilitation of old quarries is a short-term solution, the recycling of limestone waste in a cement plant has been thrown over board because of public pressure. Land reclamation is considered by some quarters as being technically difficult and financially expensive. Yet, a number of Maltese companies such as MTRC 14 have taken a step -albeit a small step - in the right direction.

All in all, a successful waste management strategy must ensure that every entity that is a producer of waste, be it public or private, must:

� Plan ahead on how it intends to reduce, reuse and recover waste. � Dispose of waste that cannot be so managed using in-house resources to the

satisfaction of the regulating authority, or through the services of a licensed waste collector15.

As far as Municipal Waste is concerned, the composting of organic matter has started at the San’ Antnin recycling plant, but problems have been encountered in the separation of waste due to infrastructural problems and over dependence on mechanical waste separation.16 Ideally waste separation should take place at source but progress has been hampered in this area due to a lack of public incentives and a good educational campaign.

Incineration is another option that would lead away from traditional landfills. While quoting Mallorca as a perfect example of an island that:

“… will phase out incineration in favour of a fuller exploitation in favour of the 3Rs”,

Greenpeace Report: ‘No Time To Waste’ April 2000,

Greenpeace clearly rejects incineration as a viable option for Malta. However, incineration should not be so categorically rejected. It is certainly more sustainable than landfills Combustion methods in modern incinerators are highly efficient in waste reduction, as much as 90% by

13 For example, the mono-landfilling of abandoned quarries with C & D Waste, would not only allow for the

rehabilitation of old quarries, but would also keep the material available for later use. 14 MTRC believes that the time is ripe for the construction industry and the authorities to seriously consider the

adoption of a radical new approach to present operations for the industry to be able to sustain itself in the future. Indeed, the company has registered a patent in Malta for a process making bricks and panels from recycled building waste: “The company founders, Michael Trapani and Robert Calafato, who were trying to find a solution to deal with construction and demolition waste, developed the process. Eighty per cent of the material used to make the bricks and panels is derived from construction waste, with the resulting product suitable for low loads. This type of brick would not be as strong as conventional concrete bricks, but would be able to support their own weight up to a height of 3.5 metres, and would also be suitable as partitioning walls in frame structures.” Times of Malta (10/3/2001)

15 Developers may reduce excavation waste by using it to landscape the site and make arrangements with an owner of a disused quarry to deposit the rest. Manufactures and importers of goods may collect and recover empty packaging that result from the sale of their product. They may also take back end of life vehicles, tyres, white goods and other products, when these become unusable.

16 An efficient waste separation facility cannot operate efficiently without manual operation.


volume and 70% by weight, it is claimed. Moreover, there is the added advantage of energy recovery. Furthermore, certain chemicals and health care wastes should not be dumped in landfills, even engineered ones. According to Prof. Alfred Vella even the microwave option, once proposed as a substitute to St. Luke Hospital’s incinerator was not a foolproof method in eliminating the risk of dispelling disease.

Directive 2000/76/EC17 on the Incineration of Waste, aims at ensuring the full combustion of waste and therefore the maximum level of incineration possible. This would prevent or - where that is not practicable - reduce the negative effects on the environment caused by the incineration and co-incineration of waste. In particular, it aims at reducing pollution caused by emissions such as NOx, into the air, soil, surface water and groundwater, and thus lessen the risks that these pose to human health. This is achieved through stringent operational conditions and technical requirements and by setting up emission limit values for waste incineration and co-incineration plants within the Community. Indeed, the Directive permits incinerators only if they are:

“designed, equipped and operated in such a manner that environmental pollution prevention requirements in the form of emission limits and management controls have been met.”

Given the Maltese reputation for flouting every possible rule or regulation, it would be a hard task indeed convincing the general public and NGOs that incineration would be an attractive waste management option for Malta. The fervent emotions evoked by the cement plant debate, a couple of years ago puts paid that.

Yet, a small island State, Singapore – albeit a rich and highly developed one - has invested heavily on state-of-the-art incineration plants. There, land is a very scarce commodity with a lot of other competing needs. The only landfill in Singapore was closed down in 1999 and the government has since set up another landfill – offshore; the Semakau landfill. It is claimed that this offshore landfill, together with four incinerator plants will meet the refuse disposal needs of Singapore, for the foreseeable future.

The latest waste-to-energy incinerator plant to be built, Tuas South Incineration Plant cost the Singaporean taxpayer a hefty $900 million. But the Singaporean government claims that it is a “green” plant18. Even Cyprus19, where the EU’s Council of Ministers recently approved the construction of a hazardous waste treatment and disposal facility, including a central incinerator, is keeping its options open as regards waste incineration.

17 This Directive enacted in 2000 covers the incineration of hazardous (formerly Directive 94/67/EC) and non-

hazardous waste (89/369/EEC and 89/429/EEC)

18 http://www.env.gov.sg/info/press/pr99/rel-161-2000.html Built at a cost of $900 million, Tuas South Incineration Plant (TSIP) Singapore’s fourth waste-to-energy plant can incinerate 3,000 tonnes of refuse every day through its six incinerators. TSIP is a "green" plant, helping to conserve portable water resources by using industrial water pre-treated by its own water reclamation plant for use in the boilers. The reverse osmosis water reclamation plant, which makes use of the latest membrane technology, will save the plant approximately 194,000m3 of potable water annually. The plant will also not consume any of Singapore's present electricity resources. Rather it will generate 80 MW of electricity, 80% of which will be made available for the public to use. Together the four plants supply about 2 % of Singapore's overall electricity consumption. Like all the other incineration plants, ferrous metals are recovered for recycling. The amount of wastewater discharged from TSIP is also minimised by way of a design, which allows wastewater drainage from the refuse bunker to be collected and pumped back into the bunker for dust suppression and eventual destruction in the furnace. Incineration reduces the volume of waste substantially, by as much as 90%. As land is limited in Singapore, ENV has adopted the policy of incinerating all incinerable waste in order to conserve land. Incineration infrastructure however does not come cheap. ENV has spent $1.83 billion building these four incineration plants and $610 million for the offshore Semakau Landfill. New Features In Singapore's Largest And Newest Incineration Plant (Press Release )

19 http://www.cyprus-eu.org.cy/eng/09_position_papers/chapter_22.htm


In spite of teething problems20, the underlying objective of the EU Directives on hazardous waste is to bring about greater harmonisation in the management of such waste. It lists the constituents and properties that render waste hazardous, and the establishments, which carry out their own waste disposal, will need a license. Hazardous waste management plans have to be published by the competent authorities, either as part of the general waste management plan (according to 75/442/EEC) or separately. Under these Directives Member States are required to:

i. identify and register every site where hazardous waste is delivered ii. introduce packaging and labelling when hazardous waste is collected, transported and

temporarily stored and this according to Community and international standards

The competent authorities must also inspect installations producing and receiving hazardous waste as well as the means of transporting the waste.

In spite of incineration being a possible, albeit expensive, option for a small island state such as Malta, landfills will still remain necessary. The ashes from incineration plants and the un-composted sludge21 from sewage treatment plants will still have to be disposed of.

As long as they are well planned, well managed, constantly monitored, and the restorations of the landscape - along with aftercare criteria - are ensured; engineered landfills can be rendered relatively safe and acceptable. Indeed, the stringent requirements and regulations22 imposed by Council Directive (99/31/EC) on each and every stage of a landfill’s life cycle, ensure precisely that.

Of course, in a discussion of how to reduce amounts of waste going to landfills it is important to look at the factors of policy, capacity, and the prices of treatment. An analysis in EU countries shows that, on an average, capacity will be exhausted in ten years from now, while price structure on the waste management market shows that in almost all countries it is cheaper to landfill waste than to incinerate it. (Christian Fischer; Waste in The EU at the Turn of the Century, Dec 1999)23

In a scenario where landfills remain relatively cheap, and externalities unaccounted for, market forces will direct waste to landfills. This situation should be changed, if the EU’s waste strategy is to be complied with. EU Directives are only one step forward. Other solutions namely the implementation of economic instruments such as landfill taxes or waste taxes should be considered if waste is to be diverted away from landfill.

Regulation 259/93/EEC on the supervision and control of shipments of waste within, into and out of the EU, establishes a system for controlling the movement of waste which implements the Basle Convention, the OECD Council Decisions on trans-frontier movements of waste and the fourth Lome` Convention24.

20 The fact that several difficulties are associated with defining hazardous waste was made evident when the EU

itself had to postpone the implementation of Directive 91/689 by drafting Directive 94/31/EC. Initially, an exhaustive list of hazardous wastes was to have provided a legally binding definition of hazardous waste. But this proved impossible to compile.

21 Waste sludge from the Sant’ Antin sewage treatment plant, which is currently being dumped at sea will have to be either composted or land filled once regulations protecting the marine environment are put into force.

22 These requirements and regulations are summarised in the Appendix to this assignment. 23 European Topic Centre on Waste - Reference: ISWA Times 4/99) 24 Whilst the Basle Convention deals only with hazardous waste, the Regulation also covers shipments of non-

hazardous waste. The Regulation sets up separate regimes governing shipments within the EU, imports, exports


Not being an OECD country, Malta invariably benefits from the "Basel ban" as no EU. country can export to it hazardous waste for disposal. As regards green waste, only certain types (basically, metal, rubber and agro-food waste) can be exported to Malta under normal commercial transactions. Due to its small size, its intense land use conflicts, the preciousness of its water resources, its fragile ecosystems and its high reliance on tourism, Malta should seriously consider the introduction of a blanket prohibition on the shipment of amber and red list wastes as per Art. 4(3)(a)(I) of the Regulation, and extend this to cover green waste as well.

The government’s proposed amendments to the Environmental Protection Act as well as its prospective waste management policy should be in line with Art. 7(4)(a) and (b) of the Regulation. This would, in accordance with Art. 7(3) of Directive 75/442/EEC, necessitate, the introduction and implementation of measures to protect the environment and public safety and health, from the hazards brought about by the shipment of amber and red list waste for recovery.

All in all, any effective waste management plan for a small island state such as Malta must take into account such aspects as:

• the use of so-called clean technologies in industry, • separate collections of waste fractions, • the use of recycled stone in the building industry, • the use of recycled materials in public projects, • the environmental impact of storage, treatment and recycling of waste in Malta, • the potential for export of waste fractions, • the policy instruments that must be introduced to make it worthwhile to reduce, reuse

and recover waste, rather than to dispose of it.

Estimating how much waste will need to be disposed of and establishing whether this fraction should go for incineration and landfill or only landfill will determine the type and amount of investment required.

The strategy should establish what national infrastructure would be required (such as facilities for the separate collection and recovery of waste), and how and where the required infrastructure would be built and how it would be operated be it public, private, or a joint venture.

Establishing the economic and legal instruments, such as the licensing of all entities that store, collect and transport, treat, recover and dispose of waste, inspections of installations, effective enforcement of regulations and prosecutions in case of transgression, that are required in order to ensure that the strategy is being implemented is also important. Those that produce more waste, and in particular those that produce more problematic waste, would have to pay more. Introducing the ‘polluter pays principle’, irrespective of whether an entity is private or publicly owned, would set the road towards ensuring the efficient allocation of economic resources and hence sustainability.

The basis of sustainable waste management is the division of responsibilities among all the various stakeholders, with the government acting as a policy ‘director’ and ‘overseer’ safeguarding public health and protecting the environment. This entails a holistic process

and transit shipments and the different requirements depend on whether the waste is destined for recovery or disposal, and whether it is listed in the annexes of the green, amber or red list. In general terms, it can be said that the amber and red lists consist of hazardous waste and the green list consists of the non-hazardous waste.


integrating economic, environmental and social issues as well as technological innovations. Above all it entails a cultural change, a change that is difficult for all countries, but even more so, for small island states - given their size, limited resources and relative insularity.

Whilst waste management issues in large industrialised states and in small developing states are clearly not identical; the adoption of tried, tested and proven solutions suitable to the particular characteristics of small island developing states is not so daunting as to require hyperbolical solutions. Clearly defined objectives, feasible plans and a well-informed and educated population; coupled with modern technology as well as foreign technical and financial aid, are the surest road towards sustainable waste management.


Bibliography

Aspinwall E. et al., Feb. 2000: Waste Management Subject Plan for the Maltese Islands – Consultation Draft, PLO 190001A , Planning Authority

Briguglio M. and Briguglio L: Economic Aspects of Waste Management in Small Island States in BOV Review No 15. Spring 1997.

Briguglio Lino Profs, 1999: UNEP Meeting of Experts on Waste Management in Small Developing States, Islands and Small Islands States Institute of the Foundation for International Studies, University of Malta.

Environmental Protection Department (1999): “State of the Environment: Summary Report for Malta” 1998 Malta University Press.

Daniel David E., 1993: Geotechnical Practice for Waste Disposal, Chapman & Hall, ISBN 0-412-35170-6

Director General, Works Division, Jan. 2000: A Solid Waste Management Plan for Malta (2000-2009) Consultation Document, Ministry of the Environment.

Manser A.G.R. and Keeling A.A : Processing and Recycling Municipal Waste, Lewis Publishers, 1996 ISBN 1-56670-164-3.

UNEP Report 1998: “Global State of the Environment, Report 1997” www.unep.org/

Rees J., 1990, Natural Resources: Allocation, Economics and Policy, Routledge, London

D.Stanners & P.Bourdeau, 1995: “Europe’s Environment, The Dobris Assessment”, European Commission and European Environmental Agency, ISBN 92-826-5409-5

Williams P.T: 1998, Waste Treatment and Disposal, John Wiley & Sons ISBN 0-471-98149-4

UNIVERSITY OF MALTA Junior College · Malta produces about 1.6 million tonnes of solid waste per...

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