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AWD Publications: Soil Society paper on Hazardous waste Classification

DESIGNATION & CLASSIFICATION OF HAZARDOUS WASTES

Stephen Moore, Shin-Yu Tu
School of Civil Engineering, University of NSW
PO Box 1 KENSINGTON NSW 2033

ABSTRACT

The background to the development of hazardous waste classification systems in Australia and overseas is provided as an introduction to an outline of current systems used in Australia. A description of the major international systems which need to be used for the export or import of hazardous wastes under the Basel Convention on Transfrontier Movement of Hazardous Wastes, and the OECD system are also provided. The important distinction between designation, used for Regulations, and classification , used for cross-jurisdictional data collection and monitoring is highligted. This paper concentrates on classification systems used in Australia.

1 BACKGROUND

1.1 Roles and Responsibilities of Various Organisations in the Management of Hazardous Waste in Australia

In addition to Regulatory bodies at the Commonwealth, State and Local Government levels, there have been a series of ad-hoc taskforces formed through-out the 1980's to the current day, to address specific issues related to hazardous waste. The issues associated with intractable waste ( a sub-set of hazardous waste) have received particular attention. A series of reports have been produced and are referred to through - out this paper, especially those to which the author was a contributor. The roles of these groups are outlined below in the hope that confusion between them will be minimised.

Following the recommendation in the 1983 AEC report (Maunsell, 1983) on the Management and Disposal of Hazardous Industrial Waste in Australia, in which a major recommendation was to establish a high temperature incinerator, a number of State government organisations and one private company attempted to establish a National High Temperature Incinerator. All these individual attempts failed, and in 1987 the first of a series of joint inter-governmental taskforces were formed. In chronological order of formation these were :

  • September 1987 : Joint Taskforce on Intractable Waste ( often shortened to "Joint Taskforce" ), composed of four independent members and reporting to the Ministers for the Environment in Victoria, NSW and the Commonwealth. It produced three major reports, with the Phase 3 report being published in September 1990.
  • January 1991 : Independent Panel on Intractable Waste ( shortened to "Independent Panel" ), composed of a separate four independent members, again reporting to the governments of Victoria, NSW and the Commonwealth. Their brief was to review the recommendations of the Joint Taskforce and to oversee the EIS for a preferred management method for intractable waste. Their final report was submitted in November 1992. The recommendations in this report were essentially to stockpile intractable wastes (henceforth to be called "Scheduled Wastes") until alternative , non - incineration, treatment technologies could be demonstrated to be effective.
  • December 1992 : The Scheduled Wastes Working Group (SWWG) was formed to coordinate and oversee the implementation of eh Independent Panel's recommendations. This Group is composed of EPA representatives from NSW, Victoria and the Commonwealth, and representatives from trade union and community based organisations. It is currently active and is likely to have a life of up to a decade.

These organisations will be referred to by their abbreviated names through - out this paper.

1.2 What Are Hazardous Wastes?

Concern over the management of hazardous wastes first arose in the 1970's when it was discovered that drinking water supplies drawn from unconfined aquifers, largely in North America, were being contaminated by uncontrolled dumping of industrial wastes in landfills and impoundments. How was this situation allowed to develop?

Increasingly stringent air and surface water discharge standards developed in the 1960's led to the introduction of improved air pollution and water pollution control technology in industry. These treatment plants removed contaminants from emissions to the atmosphere and surface waters (either via the sewerage system or directly) and concentrated them in sludges and dusts. These residues were then dumped in solid waste landfills or surface impoundments, either on the site of the generator or, more often, at offsite facilities. These facilities had little control on the nature of residues being accepted and provided little security against leakage to groundwaters. As a result, leachate from these facilities migrated to groundwater and eventually appeared in wells extracting water for town supplies.

Two responses occurred as a result of the discovery of the environmental impacts of the uncontrolled disposal of industrial wastes:

  • Programs to clean up contamination from past activities, such as the Superfund (CERCLA) program in the USA.
  • Development of comprehensive systems to properly manage industrial wastes so that the ongoing generation of wastes would not continue to degrade environments, particularly groundwaters (eg RCRA legislation in the USA).

This paper is primarily concerned with the development of classification systems for the ongoing generation of comprehensive management systems. However, there are overlaps with contaminated site remediation and these will be briefly discussed. Contaminated site remediation has developed into a field in its own right because of the often complex mixtures of contaminants that arose from the uncontrolled disposal of wastes.

1.3 Approaches to defining Hazardous Wastes

Fundamental to the management of hazardous waste is the need for an adequate definition to provide bounds to the problem. The task of providing an adequate definition is not straight forward because of "the tremendous scope of adverse human and environmental effects which may be caused by an almost boundless list of environmental contaminants. Against this background, almost any definition will seem simplistic and inadequate" (Hrudey, 1985).

However, nothing can be achieved until a workable definition is agreed to.

Currently (1993), there are significant changes occurring in the administration of environmental controls in a number of States and at the Federal level. This includes extending the geographic extent of control over hazardous waste and the revision (or design of) hazardous waste regulations. A thorough appreciation of the background to current classification systems and a critical review of them is essential for the design of new and more comprehensive systems. These new systems are currently being develped and it hoped that this paper will provide a constructive input to their develpment.

With this in mind, this paper aims to:

  • provide an understanding of the constraints on the design of designation and classification systems and to explain how current systems have evolved.
  • provide the background and a framework on which future more rational classification systems can be based.
  • describe current systems and possible future changes to these systems.

2 DESIGNATION AND CLASSIFICATION OF HAZARDOUS WASTE

Designation of a waste as a hazardous waste refers to the regulatory procedure that legally determines that a particular waste is caught in the hazardous waste control system for a particular region; it is normally written in Regulations under an Act controlling the management of wastes. Classification of hazardous wastes is the system that facilitates the monitoring of wastes after they have been caught in the hazardous waste control system by the designation procedure. The approaches to designation and classification systems are reviewed in the following section before this distinction is revisited in more detail. (Wynne, 1987).

Three approaches, and sometimes a mixture of these approaches, have been used in the development of designation and classification systems, namely:

  • generalised definitions
  • exclusionary definitions
  • inclusionary definitions.

The application of these approaches to designation and classification systems are explained in this section.

2.1 Hazardous Waste Designation Systems

2.1.1 Generalised Definitions

Generalised definitions are often provided in legislation and guidelines on hazardous waste management. They are important in providing a succinct description of the scope of the legislation/guidelines, but have limited immediate usefulness for the administration of hazardous waste systems or the conduct of research and development. They must be interpreted in order to build up a workable list of wastes which are hazardous.

"A hazardous waste is thus defined as any waste, excluding domestic and radioactive waste which, because of its quantity, physical, chemical or infectious characteristics, can cause significant hazards to human health or the environment when improperly treated, stored, transported or disposed" (WHO, 1987).

"Hazardous waste means a solid waste, or combination of solid wastes which, because of its quantity, concentration or physical, chemical or infectious characteristics, may:

(a)cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or

(b)pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported or disposed of, or otherwise managed" (US. Act 94/580, 21 Oct., 1976).

"Hazardous waste means waste that requires special precautions in its storage, collection, transportation, treatment or disposal, to prevent damage to persons or property and includes explosive, flammable, volatile, radioactive, toxic and pathological waste" (Ministry of the Environment, Ontario, 1983).

"Hazardous waste means any waste other than radioactive waste considered as hazardous or legally defined as hazardous in the country where it is situated or through which it is conveyed, because of the potential risk to man or the environment likely to result from an accident or from improper transport or disposal." (OECD, 1990)

From these examples, it can be seen that generalised definitions of hazardous waste consist of one or more of the following components:

Hazardous waste is a waste, which:

  • may adversely affect human health
  • may adversely affect other living organisms
  • may damage property.

All these definitions assume a definition for waste. This is sometimes not well defined in legislation, and a suggested definition is :

a waste is a material which has negative value for the current owner, ie it currently costs the owner to manage the material at this time in its current location (this does not preclude the material having value to someone else at another location and/or at a future time - these are important issues for the management of the material which are beyond the scope of this paper).

2.1.2 Exclusionary Definitions

In general terms, hazardous wastes can be defined on an exclusionary basis i.e. they are wastes which are excluded from being disposed of to conventional waste management systems of:

  • Municipal solid waste landfills, and
  • Sewerage systems.

These conventional systems often have discharge acceptance criteria (trade waste discharge criteria for sewers, and lists of excluded wastes for municipal solid waste landfills) and hence any wastes which are not allowed to be disposed by these routes become, by this definition, hazardous wastes. In some countries (Canada, U.K.), these wastes are known as 'Special Wastes', which avoids the problem of whether they are actually hazardous or not.

While the exclusionary basis is logically comprehensive, it is a difficult means for Regulators to employ in controlling the generation and fate of hazardous wastes. While this exclusionary definition was used in the U.K. for a time, it is not now generally used in practice. It remains, however, a useful concept to aid in the appreciation of where hazardous wastes fit in the overall picture of waste management. It is still used in practice in Sydney for designating hazardous wastes.

2.1.3 Inclusionary Definitions or Designation

Inclusionary definitions seek to define hazardous wastes by providing criteria or an inclusionary list which, if wastes satisfy these, designates them as hazardous wastes. There are three types of inclusionary definitions:

  • Generic definitions
  • Constituent definitions
  • Characteristic's definitions

Most Regulatory agencies in Australia use a combination of the first two, the US EPA (CFR40, 1990) and the Basel Convention (UNEP, 1989) use a combination of all three. The draft proposal for designation of non-BAT wastes in N.S.W. used a combination of all three along the lines of the Basel Convention (Joint Taskforce on Intractable Wastes, Phase 3 report).

Generic definitions are based on a description of the process from which the waste arises. For instance, sludge from the bottom of oil storage tanks, and distillation bottoms from solvent recovery plants.

Constituent definitions designate wastes as hazardous if they contain measurable concentrations of certain hazardous compounds. For instance, wastes which contain arsenic, or chlorinated solvents, or lead. In Australia the concentration or mass load of a constituent is not often employed in the definition - whether or not the concentration of a constituent is of concern is left to the judgement of the Regulator. North American and European practice is to include the concentration and mass of the constituent that makes the waste hazardous. The inclusion of concentrations and mass of constituents is now being employed in the N.S.W. Chemical Control Orders for chemical wastes and the definition of Scheduled (formerly intractable ) Waste.

Wastes can also be designated as hazardous if they exhibit one or more of the following hazardous characteristics:

  • Toxicity
  • Flammability
  • Reactivity
  • Corrosivity.

The tests for determining each of these characteristics are not yet fully developed. Tests for toxicity characteristics are subject to the greatest debate ( Francis et al, 1989). The test gaining acceptance in Australia is the US EPA Toxicity Characteristic Leaching Procedure (TCLP), which, in Australia, designates a waste as hazardous if the leachate from the waste has concentrations of toxic constituents greater than 100 times that allowed in drinking water. Standards Australia is modifying this test for an Australian Standard which is likely to become a component of a number of Australian regulations defining hazardous waste.

While most inclusionary definitions are simple lists with a combination of the above three approaches, the latest definitions developed for the Basel Convention and the non-BAT waste designation (Joint Taskforce on Intractable Waste, Phase 3 report) follow a more rigorous rationale; namely:

a waste is designated as a non-BAT hazardous waste if it is contained in a generic list of wastes, or contains one or more constituents of concern at concentrations and mass above threshold levels, and the generator has failed to demonstrate that the waste does not exhibit any of the four hazardous characteristics.

This designation allows the generators to de-List their wastes by demonstrating that they do not exhibit, according to standard agreed tests, any hazardous characteristics. Dilution of constituents to achieve this state is not allowed. However, there are practical difficulties which would mean that few generators would attempt to de-List their wastes.

2.2 Hazardous Waste Classification Systems

The discussion above has outlined how hazardous wastes are defined or designated, i.e. a means whereby the wastes so identified can legally be required to be controlled by the hazardous waste management system. A separate concept is that of classification systems which are used to categorise hazardous wastes to facilitate data collection and their management. Classification systems are sometimes coarser than designations and are often easier to apply in practice, and sometimes contain additional useful information not required for the legal purposes of the designation system. However they can also be derived from, or incorporate, the designation lists and criteria.

In summary, designation methods determine whether or not a waste is hazardous; once it is determined to be hazardous, the hazardous waste classification system tends to be used to identify the waste, collect statistics on its occurrence, provide additional information on the waste's characteristics to assist in its management, and to track its movement.

The classification system developed by the Australian Environment Council in 1986 (now the Australian and New Zealand Environment and Conservation Council, ANZECC), as shown in Table 1, has now been adopted in South Australia, Victoria and in Sydney by the former Waste Management Authority of N.S.W. and the new EPA. A draft report indicates that Tasmania is also likely to adopt the AEC standard (Tasmanian DEP, 1991). Brisbane and Western Australia have simplified versions which can be converted to the AEC system if required.

Table 2 shoows how the AEC system has been applied in Sydney in the Waste Disposal Act. ANZECC is in the process of drafting a revised system which will be used in the National Waste Manifest system which will be used for intra and inter - state movement of hazardous wastes (see Section 5).

3 BASEL CONVENTION

Australia is a signatory to the Basel Convention on Transfrontier movement of Hazardous Wastes and must use the Basel Convention classification system on documentation associated with the import and export of hazardous wastes from Australia (to date there has only been a single shipment from Australi to France under this Convention. The UK, where Australia disposed of intractable wastes in the 1980's, is not a signatory to the Convention. Currently there is a two year moratorium on the export of hazardous wastes from Australia ).

3.1 Hazardous Waste Designation

The Basel Convention designation of hazardous waste, for the purpose of defining those wastes subject to the Convention, is provided in Article 1 of the Convention :

1. The following wastes that are subject to transboundary movements shall be "hazardous wastes" for the purposes of this Convention :

(a) Wastes that belong to any category contained in Annex I, unless they do not possess any of the characteristics contained in Annex III; and

(b) Wastes that are not covered under paragraph (a) but are defined as, or are considered to be, hazardous wastes by the domestic legislation of the Party of export, import or transit.

Annex I and Annex III are provided in Appendix I. Annex I is made up of two parts :

"Waste streams" which largely follow the generic approach described above, and

"Wastes having as constituents" which follows the constituent approach described above.

Annex III is a list of hazardous characteristics, the third approach described Section 2.1.3.

3.2 Hazardous Waste Classification

The Basel Convention requires the completion of two forms that are similar in intent to the conventional waste manifest four docket system, and requires waste classification information to be provided in those forms, namely :

Information to be Provided on Notification :

  • "Y" number (part of the designation system from Annex I, refer Appendix I)
  • Physical description (liquid, sludge, solid)
  • UN Number (the UN code number for waste dangerous goods, per List 2 of the 1986 AEC Guidelines)
  • Composition (nature, eg toxicity, and concentration of the most hazardous components)
  • "H" Code number from Annex III, refer Appendix I
  • Method of disposal, per Annex IV, refer Appendix I

This information is essentially a six field classification system.

Information to be Provided on the Movement Document :

  • "Y" number from Annex I
  • Physical state of the waste
  • UN Number
  • "H" Code number from Annex III

ie a four field classification system which is a derivative of the classification system used for the Notification document.

It can be seen that the Basel Convention classification system (even though it is not explicitly described as such) has used most of the designation system, and added fields to it, to provide more information about the waste in a convenient form that facilitates the management of the waste, particularly in the case of a spill.

4 OECD ENVIRONMENT MONOGRAPH No 34

4.1 Hazardous Waste Designation

For the purposes of the OECD Decision on Transfrontier Movement of Hazardous Waste, wastes are designated as hazardous wastes if they appear in a Core List or are defined as such by member country legislation, namely :

For the purposes of this Decision (Decision on transfrontier movements of hazardous waste, C(88) 90 (final)) those wastes which belong to any of the categories described in Table Y shall be controlled unless such wastes do not possess any of the hazardous characteristics listed in Table 5; and

all other wastes which are considered to be or are legally defined as hazardous wastes in the Member country from which these wastes are exported or in the Member country into which these wastes are imported.

The Core List, or Table Y is provided in Appendix II and can be seen to be very similar to , but not exactly the same as, Annex I from the Basel Convention. Table 5 in the OECD monograph is similar to Annex III in the Basel Convention, and is provided in Appendix I.

4.2 Hazardous Waste Classification

The OECD Decision is explicit in providing a separate complete characterisation of hazardous wastes to assist in their management after the waste has been caught within the controls of the Decision. The International Waste Identification Code (IWIC) consists of :

Table 1 : One or two descriptors from the table of "reasons why materials are intended for disposal" - this is a very general generic type approach to classifying waste. Refer Appendix II.

Table 2 : One descriptor from the table of disposal and recycling operations. Details of the location of the disposal facility would be provided on transport documents, the main use of this field in the classification system would be in extracting information from a database on the fate of different types of hazardous wastes, and to track trends over time. Refer Appendix II.

Table 3 : One descriptor from the list of generic types of hazardous wastes, with a prefix of L (liquid), P (sludge) or S (solid). The first 17 of these are the same as Table "Y" used in the designation and for the Basel Convention; the remaining 23 are additional generic waste descriptors that are suggested for use provided they also contain constituents of concern as listed in Table 4 of the OECD monograph. Refer Appendix II.

Table 4 : Zero to three hazardous constituents in order of decreasing concern. This list is more extensive than the Basel Convention. Refer Appendix II.

Table 5 : One or two descriptors of hazard characteristics from this table, which is similar to Annex III from the Basel Convention. Table 5 is also used in the designation of hazardous wastes. Refer Appendix II.

Table 6 : One of the activities generating the waste should be selected from this table of Standard Industry Codes. Refer Appendix II.

The IWIC can be conveniently expressed in a single line with double oblique line field separators :

Q----+----//D,R----//L,P,S----//C----+----+----//H----+----//A----

This provides a very comprehensive characterisation of the waste and facilitates monitoring and management of the waste once it is designated as a hazardous waste under the Decision. It can be seen that the designation system is incorporated into the classification system.

5 FUTURE DEVELPMENTS

5.1 Revised ANZECC Classification System

The responsibility for designating wastes as hazardous wastes in Regulations under Acts governing the management of hazardous wastes lays with the States; for example, South Australia's SAWMC Act has regulations containing Schedule 2, the Prescribed Waste list which defines those wastes to be controlled in South Australia by the hazardous waste provisions of the Act (licensing of generators, manifest procedures etc). Victoria also has a Prescribed Waste List, and NSW has Chemical Control Orders under the Environmentally Hazardous Chemicals Act as well as guidelines under the Waste Disposal Act based on an exclusionary approach to defining hazardous wastes.

ANZECC is currently drafting a revised hazardous waste classification system which will be used with a National Waste manifest System, to control the movement of hazardous wastes both within and between States. The revised system is due for adoption in early 1994, and it is intended to be compatible with the Basel Convention and OECD systems described in this paper. Once in place this new system will be used for the National Waste Database

5.2 National Waste Database

5.2.1 Aim and Objectives

The aim of the project is to establish a database on waste generation in Australia which can be used by State and Commonwealth environmental and waste management agencies, and other interested organisations to set and monitor the achievement of national waste minimisation targets.

To achieve this aim, the following objectives will need to be met:

(a) Review and establish nationally agreed classification systems for various groups.

(b) Establish a protocol for sampling and characterising urban solid wastes.

(c) Establish a national waste generation database to provide fundamental information on the generation of different types of waste by region and in relation to relevant parameters.

(d) Review Australian and overseas waste generation trends and suggest waste minimisation benchmarks for each waste type by region.

The Database will cover both solid waste (non-hazardous waste arising from municipal, commercial, industrial, building and demolition activities) and hazardous waste (generally liquid industrial wastes which are precluded from disposal to the sewerage system) disposed to off-site treatment and disposal facilities. Details of the solid waste component are provided in a recent paper by Moore et al (1993). Database activities related to the hazardous waste field are described in the remainder of this section.

5.2.2 Hazardous Waste Component of the National Waste Database

Hazardous wastes for the purpose of the National Waste Database are those wastes which are not allowed to be disposed of to the sewer or to municipal solid waste landfills, and if the generator has no means or treating and disposing of them on-site, they must be tankered to an off-site treatment plant. Most of the major metropolitan areas in Australia have established manifest systems which track and record the transport of these hazardous wastes from the generator to the treatment plant, and in so doing build up a database of information on their generation; these will gradually be extended nation wide with the introduction of the National Manifest System in 1994.

The National Waste Database project, in the hazardous waste field, will :

Contribute to the revisions to the hazardous waste classification system being undertaken by ANZECC, by suggesting structures and details which will inherently improve the integrity of the data (removing potential ambiguity) and enable the Australian system to be directly compared to International systems developed by the OECD and UNEP.

Obtain aggregated monthly data on the generation of each type of hazardous waste in each region covered by a manifest system and using the national hazardous waste classification system. Data will be aggregated by industry type using 4 digit ASIC (Australian Standard Industry Classification) codes, which are entered onto the manifest forms and subsequently into the manifest database.

Transfer the monthly data into a relational database, such as dBASEIV, with the waste entity having attributes of waste type (using the revised ANZECC classification system), waste quantity, month generated, ASIC code of generator, treatment type provided, and region in which generated.

Generate standard reports on the generation of waste types in each region on a routine basis and prepare special reports on request. The design of these reports will be developed through initial consultation with users, followed by trialing and refinement.

With the exception of leaching tests for determining the hazardous characteristics of wastes, sampling and analysis protocols for hazardous wastes are unlikely to require the attention and development that will be devoted to solid wastes.

5.2.3 Linkages to Other Databases

The hazardous waste database will be a sub-set of the proposed National Pollutant Inventory (NPI), which will attempt to record all emissions from facilities in a similar manner to the US EPA Toxics Release Inventory. NPI data will have to be aggregated by region to enable it to be complementary with data from the National Waste Database. This will be easily achieved as the NPI will know either the exact location of the facility (from a GIS) or at least its postcode.

An important link to the extensive ABS database is via the ASIC code. This will enable relationships between waste generation and a range of standard economic and demographic statistics to be investigated.

ACKNOWLEDGMENTS

The National Waste Database is a project in the Waste Minimisation Program of the CRC for Waste Management and Pollution Control Ltd., which has been established and supported under the Australian Governments Cooperative Research Centres Program. The project is funded by the Commonwealth EPA and the CRC for Waste Management and Pollution Control Ltd.

Abbreviations

AEC Australian Environment Council

ABS Australian Bureau of Statistics

ANZECC Australian & New Zealand Environment & Conservation Council

ASIC Australian Standard Industrial Classification

CEPA Commonwealth EPA

CRCWMPC Cooperative Research Centre for Waste Management & Pollution Control

ESD Ecologically Sustainable Development

EQI Environmental Quality Index

GIS Geographic Information System

IGAE Intergovernmental Agreement on the Environmental

NPI National Pollutant Inventory

UNCED United Nations Conference on Environment & Development

References & Bibliography

AEC; National Guidelines for the Management of Hazardous Waste, November 1986.

ANZECC; Draft National Guidelines for Waste Minimisation, 1989.

Francis, C.W.; Maskarinec, M.P.; Lee, D.W.; Physical and Chemical Methods for the Characterisation of Hazardous Wastes; in the Landfill, Reactor and Final Storage, Springe Verlag, Berlin, 1989.

Moore, S.J.; Worrall, M.J.; Waste Management Plans for Major Industries, in Waste Technology and Management, DITAC, 1991.

Moore, S.J.; et al; Establishment of a National Waste Database for Australia; 7th National Local Government Engineering Conference, IEA; Adelaide, September 1993.

Moore, S.J., Tu, S-Y; Unit Production Indices of Hazardous Waste Generation for Measuring Environmental Performance, Munro Center for Civil & Environmental Engineering, University of NSW, Seminar, 14 July 1993.

Tasmanian Department of Environment and Planning, draft Industrial Waste Management Strategy, July 1991.

UNEP; Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, Final Act, 1989.

US EPA; 40 CFR Part 148 et al, Land Disposal Restrictions for Third Scheduled Wastes, June 1990.

APPENDIX I

Basel Convention on Transfrontier Movement of Hazardous Wastes

Extracts

APPENDIX II

OECD Decision on Transfrontier Movement of Hazardous Wastes