Basel ConventionExpert Working Group on the review of Annexes
Working document for Annex IV.B- Comments by Israel
Decision BC-13/2: Mandate for the review of Annex IV
(i)Improve/update the description of disposal operations in Annex IV; and,
(ii)Improve environmental controls by including additional disposal operations that occur in practice or could occur in practice in Annex IV.
How to use this document: Please complete the table with your comments, including ‘problem statement’, ‘proposed change’ and ‘rationale’. Leave blank if no change is required. Boldandunderlinefor additions and strikethrough (e.g., strikethrough) for deletion of text.
Submitting member/observer:
A / B / C / D / EAnnex IV.B / Problem statement / Proposed change / Rationale / General comments
Caption text
B. OPERATIONS WHICH MAY LEAD TO RESOURCE RECOVERY, RECYCLING RECLAMATION, DIRECT RE-USE OR ALTERNATIVE USES / The text is not clear and precise:
- "Direct re-use" is not an operation as it is only occurs if no operations are necessary.
- The words "may lead" add uncertainty to the definition.
Introductory text
Section B encompasses all such operations with respect to materials legally defined as or considered to be hazardous wastes and which otherwise would have been destined for operations included in Section A / The Introductory text
is not clear enough and does not help to define section B / Section B encompasses all such operations with respect to materials legally defined as or considered to be hazardous wastes and which otherwise would have been destined for operations included in Section A
Any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfill a particular function, or waste being prepared to fulfill that function, in the plant or in the wider economy” / Adding a definition that is compatible with the definition in the glossary of terms and is not already defined in the Convention, makes the content of section B and the classification of the facilities clearer.
General comments
A / B / C / D / E
Disposal operation / Problem statement / Proposed change / Rationale / General comments
R1 / Use as a fuel (other than in direct incineration) or other means to generate energy / This definition creates conflictsand may overlap with R9.
What is direct incineration? And why is this not included in recovery of energy (if it in fact uses the energy for useful purposes by replacing other fuels)? / Use as a fuel (other than in direct incineration) or other means to generate energy. / This "use as a fuel" describesthe use of waste as a substitute for energy rather than the treatment itself. This corresponds to other recovery operations such as recycling metal (R4) or plastic (R3) that do not refer to the process but to the recycled material.
The recovery process inR1 isthe use of the energy contained in the waste for a useful purpose.Any further detail may contribute to unnecessary complication and confusion.
R2 / Solvent reclamation/regeneration
R3 / Recycling/reclamation of organic substances which are not used as solvents
R4 / Recycling/reclamation of metals and metal compounds
R5 / Recycling/reclamation of other inorganic materials
R6 / Regeneration of acids or bases
R7 / Recovery of components used for pollution abatement
R8 / Recovery of components from catalysts / There is overlap with R4, R3. / Recovery Recycling/reclamation of components from catalysts / The proposed change describes the recycled material or object (catalysts)itself, that in many cases can be reused after treatment and not the"components from catalysts"that are included under R3 or R4.
R9 / Used oil re-refining or other reuses of previously used oil / Potential overlap/conflict between "other reuses of previously used oil"in R9 and R1 “use as a fuel”. / Used oil re-refining or other reuses of previously used oil / Other uses of used oil can be defined by other operationsas in the case of R1.
R10 / Land treatment resulting in benefit to agriculture or ecological improvement / Potential overlap/conflict between R10 and R5.the definition is not clear enough / Land treatment resulting in benefit to agriculture or ecological improvement
Use of waste for soil, agriculture or other ecological improvement / If the intent is to use waste to lead to ecological or agriculturalimprovement (e.g. Improving the quality of acidic or basic soil, fertilization). , then the following wording can be proposed:
Use of waste for soil, agriculture or other ecological improvement.
It should be clarified whether treatment of contaminated soil for reuse is here or under R5
R11 / Uses of residual materials obtained from any of the operations numbered R1-R10 / There is uncertaintyabout the meaning and whenaspecific treatment is to be used and when R11. / Delete / Any uses of residual material must accord with one of the R's above, so we don’t see there is aneed for R 11.
R12 / Exchange of wastes for submission to any of the operations numbered R1-R11 / There is uncertainty about the meaning of "Exchange of wastes".
Potential overlap/conflict between R12 and R13 / Exchange of wastes for submission to any of the operations numbered R1-R11.
Preparatory operations such as Blending ,mixing,washing or shreddingprior to submission to any of the operations in Section B / The proposed text resembles to the corresponding text in Section A (D13), describing the activity of mixingwaste before submission to any of the operations.
R13 / Accumulation of material intended for any operation in Section B / Potential overlap/conflict between R12 and R13.
There is lack of uniformity compared to the corresponding Disposal operation description inSection A (D14, D15). / Accumulation of material Repackaging intended for any operation in Section B.
Repackaging, including baling prior to submission to any of the operations in Section B / The proposed text is resembles to the corresponding text in Section A (D14).
For this change be completed we need to add a new operation for storage, as described in D15- Storage pending any of the operations in Section A
General comments
We think that a clear and closed list is preferable, without the possibility of classifying as "other treatment" that not classified elsewhere.
If possible, we suggest matching the numbering of the classifications of List A and B so that the description will be consistent and create less confusion.
e.g.
Preparatory operations such as blending ,mixing, washing or shredding prior to submission to any of the operations in Section B - R12 and
Preparatory operations such as blending, mixing, washing or shredding, prior to submission to any of the operations in Section A - D12
A / B / C
New R operation / Rationale / General comments
1 / Prepare for reuse / There are operations that prepare waste for reuse, for example: reuse of packages, e- waste. For these and maybe for others there is no suitable definition in the current Annex.
2 / Prepare for Reuse of e-waste including repair and refurbishment. / As there are a lot of comments about the need for new operation that describe the recovery of e-waste, it may be advisable to make a specific R forPrepare for Reuse and/or repair and/or refurbishment of e-waste.
3 / Preparatory operations such as washing, shredding or baling / There is no suitable definition in the current Annex.
Baling may be considered as type of Repackaging, as described in R13 (new suggestion).
Washing and shreddingcan be part of R12(new suggestion). / It can be part of R12 or R13 as mention above.
4 / Storage pending any of the operations in Section B / The proposed text resembles the corresponding text in Section A (D15). It creates uniformity with Section A
5 / Recovery of components not covered by other operations (e.g. Separation of materials for recovery from used vehicles and e-waste) / There are waste streams thatare composed of different materials and therefore it is difficult to classify the recovery under the existing optionsthat are limited to the recycling or recovery of a specific material.
Overarching comments
1