MINISTER OF THE ENVIRONMENT
OF THE REPUBLIC OF POLAND
QUESTIONNAIRE IN CONNECTION WITH THE
REPORTING OBLIGATION OF MEMBER STATES
UNDER REGULATION (EC) No 1013/2006
OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
ON SHIPMENTS OF WASTE
REPORTING PERIOD: 1 JANUARY – 31 DECEMBER 2008.
Questionnaire prepared by
The Chief Environmental
Protection Inspector
Warsaw, November 2009
ADDITIONAL QUESTIONNAIRE FOR REPORTS BY MEMBER STATES
PURSUANT TO ARTICLE 51(2) OF REGULATION (EC) No 1013/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON SHIPMENTS OF WASTE
Article 11(1)(a) / Information on the measures taken to prohibit generally or partially shipments of waste between Member StatesIn order to implement the principles of proximity, priority for recovery and self-sufficiency at Community and national levels in accordance with Directive 2006/12/EC
Has this provision been applied? YesNO
(please tick √ as appropriate) √
If yes, please provide details of the measures taken:
------NOT APPLICABLE ------
Additional remarks:
------NOT APPLICABLE------
Information on the measures taken to object systematically to shipments of waste between Member States
In order to implement the principles of proximity, priority for recovery and self-sufficiency at Community and national levels in accordance with Directive 2006/12/EC
Has this provision been applied?YesNO
(please tick as appropriate)√
If yes, please provide details of the measures taken:
------NOT APPLICABLE------
Additional remarks:
------NOT APPLICABLE------
Article 11(1)(e) / Information on the prohibition of the import of waste
Has this provision been applied? YESNo
(please tickas appropriate) √
If yes, please provide details on the measures taken:
2008 saw the entry into force of the Decree by the Minister of the Environment dated 24 June 2008on types of waste whose importation for the purpose of disposal is prohibited (Journal of Lawsdated 7 July 2008, No 119,item 769), which was adopted in application of Article 11(1)(e) of Regulation No 1013/2006.
Article 11(3) / Information on exceptions to the implementation of the principle of proximity, priority for recovery and self-sufficiency
In the case of hazardous waste produced in a Member State of dispatch in such a small quantity overall per year that the provision of new specialised disposal installations within that State would be uneconomic
Have you asked any Member State to apply this exception?
Yes NO
(please tick √ as appropriate) √
If yes, please complete Table 1 and give details below of any bilateral solution found pursuant to Article 11(3).
------ NOTAPPLICABLE ------
Have you received any request from Member States to apply this exception?
Yes No
(please tick √ as appropriate)
If yes, please complete Table 1 and give details below of any bilateral solution found pursuant to Article 11(3):
------NOT APPLICABLE------
Article 11(1)(g) / Information on objections to planned shipments or disposal on the basis of their not being in accordance with Directive 2006/12/EC.
Has this provision been applied? YESNo
((please tick √ as appropriate) √
If yes, please complete Table 2.
Article 12(5) / Information on objections to planned shipments or recovery on the basis of their not being in accordance with Article 12(1)(c).
Has this provision been applied? YES No
(please tickas appropriate) √
If yes, please complete Table 3.
Article 14 / Information on decisions by competent authorities having jurisdiction over specific recovery facilities to issue pre-consents to such facilities
Has this provision been applied?YES No
(please tickasappropriate) √
If yes, please complete Table 4.
Article 33 / Information on the Member States' system for the supervision and control of shipments of waste exclusively within their jurisdiction
Is there a system for the supervision and control of shipments of waste within the jurisdiction? YES No
(please tick asappropriate) √
If there is such a system, do you apply the system provided for in Titles II and VII of the Regulation? Yes NO
(please tick as appropriate) √
If you apply a different system from that provided for in Titles II and VII of the Regulation, please give details of the system applied:
The Waste Act of 27 April 2001, transposing into Polish law the framework Waste Directive (2006/12/EC), lays down rules for waste management.
In Poland, the Environmental Protection Inspectorate oversees compliance with proper waste management.
The Waste Act requires owners of wastecarrying out the collection or transport thereof to have authorisation to engage in such activities.Such authorisation is issued by the "Starosta" – the head of the district authority.
The Road Transport Inspectorate verifies road transport compliance, including the transport of waste within Poland.
Article 24 and Article 50(1) / Information on illegal shipments of waste
Has there been any case? YESNo
(please tick as appropriate) √
If yes, please complee Table 5.
Please provide information on how illegal shipments of waste are prevented, detected and penalised under national legislation:
- PREVENTION, DETECTION
Joint checks on international shipments of waste have been carried out primarily:
- at border crossings – checks carried out by border guards or customs officials at border crossings on the EU external border, including at seaports, with the involvement of the Environmental Protection Inspectorate;
- on national roadsand in areas close to the EU external border – checks carried out by inspectors of the Road Transport Inspectorate, mobile customs and border guard units and the police, with the involvement of the Environmental Protection Inspectorate.
- PENALISATION
Chapter 8 "Penalties”
Any person who fails, in breach of an obligation, to carry out a decisionordering the return of imported waste to the countryof dispatchor stipulating the method of managing that waste in Polandshall be subject to imprisonment or a fine.
Chapter 9 "Fines”
The illegal importation of waste into Poland or its exportation from Poland shall be subject to a fine of PLN 50000 to 300000.
Chapter 9 of the Act also provides forpenalties of PLN30000 to 150 000 for violations of the conditions set out in a permit for lawful shipments of waste.
Penal Code Act of 6 June 1997 (Journal of Laws No 88, item 553, as amended) – Article 183 of the Penal Code::
"Article183.§1. Anyone who, in breach of statutory provisions, stores, disposes of, processes, renders harmless or transports waste or substances under such conditions or in such a manner as to endanger the life or health of human beings or causedestruction of plant or animal life to a significant extent shall be subject to a term of imprisonment of between 3 months and 5 years.
§ 2. The same punishment shall be imposed on anyone who, in breach of statutory provisions, imports waste or substances hazardous to the environment.
§ 3. The punishment specified in § 1shall be imposed on anyone who, in breach of an obligation, allows an offence specified in § 1, 2 or 4 to be committed.
§4.The punishment specified in § 1 shall be imposed on anyone who imports or exports waste in breach of statutory provisions.
§5.Anyone who imports or exports hazardous waste without making the required notification or without permission, or in breach of the conditions set out therein, shall be subject to a term of imprisonment of between 6 months and 8 years.
§ 6. If the perpetrator of an offence specified in § 1-5 acts unintentionally, heshall be subject to a fine, restriction of liberty or a term of imprisonment of up to 2 years."
Article50(2) / Information on spot checks on shipments of waste or on the related recovery or disposal
Number of checks on shipments of waste or on the related recovery or disposal:177 checks on facilities and around 2400 checks on consignments shipped..
Number of supposed illegal shipments ascertained during these checks:
6 confirmed cases of illegal shipment
The checks were carried out by the Voivodship (Regional)Environmental Protection Inspectorates during inspections – either scheduled or requestedby the Main Inspectorate or other bodies – of economic operators engaged in the operation of waste-recovery facilities. Checks on businesses were carried out prior to the issue of a permit for the cross-border shipment of waste as well as after a permit had been issued.The inspectors usually checked whether the particular operatorwas importing waste without the requisite permit. Where the operator was in possession of a permit, a check was made on compliance therewith in terms of the types, quantities and proper handling of the waste imported.
In 2008, a total of 177 checks were carried out on installations associated with cross-border shipments of waste. In the course of these checks, three illegal shipments were discovered, and in two other cases the matter was dropped following an investigation.
Joint road and border checks were carried outunder IMPEL TFS projects, inter alia, and in the context of bilateral cooperation with Germany. Within the framework of IMPEL TFS projects, around 60 checkpoints were set up nationwide, and almost2400 shipments were checked during the operation. In three cases, illegal shipments of waste were detected.
In addition, Voivodship Environmental Protection Inspectorates conducted a number of other activities to combat illegal shipments of waste into Poland.These activities mainly comprised:
- the examination, at the request of other bodies, of goods/substances detained during border or road checks, in order to determine whether they met the definition of waste;in total, inspectors of the Environmental Protection Inspectorate carried out 204 such examinations of goods;
- the submission to other bodies, at their request, of a written opinion on whether particular goods qualified as waste (around 200 such opinions), or the provision of information concerning operators which had been the subject of a preparatory investigation relating to illegal shipments of waste –at the request of the police,
Article 6 / Information on a financial guarantee or equivalent insurance covering costs for transport, recovery or disposal and storage of waste, including cases referred to in Articles 22 and 24
Please provide details on the provisions of national law adopted pursuant to this Article
Decree by the Minister of the Environment dated 21 May 2008 concerning the method of calculating the amount of the guarantee(Journal of Laws dated 5 June 2008, No 96, item 618 )
The financial guaranteemust cover the period from the commencement of a waste shipment to the provision of a certificate to the effect that the waste has undergonerecovery or disposal.
Financial guarantees may be provided in the form of a bank guarantee, an insurance guarantee or a deposit.
The amount in respect of which guarantees are to be established is determined by the competent body in the country from which the waste is dispatched - in Poland the Main Environmental Protection Inspectorate (GIOŚ).
The guarantee amount (in PLN) is calculated according to the following formula:
G = (D + T + M) x A, where:
G - is the amount of the guarantee;
D - is the cost of disposal or recovery,including any necessary interim operation, of one tonne of notified waste;
T- is the cost of transport of one tonne of notified waste from place of dispatch to place of destination;
M - is the cost of storing waste for a 90-day period, which per tonne of:
- non-hazardous solid wasteis PLN 200,
- hazardoussolid wasteisPLN 500,
- non-hazardous liquid waste isPLN 500,
- hazardous liquid wasteisPLN 1000 PLN;
A - is the weight, in tonnes, of waste covered by the guarantee.
In the event of the provisions of a bank- or insurance-guarantee contract or the guarantee amount not ensuring coverage of the costs referred in Article 6(1)of Regulation No 1013/2006, the Chief Environmental Protection Inspectorshallorder that the provisions of the bank- or insurance-guarantee contract or the guarantee amount be supplemented accordingly.
Itis permissible to lodge a complete guarantee covering all planned waste shipments or a partial guarantee in respect of a given volume of shipments declared by the notifier.
After an international shipment of waste has been completed and the documents required under Regulation No 1013/2006 have been produced, the Chief Environmental Protection Inspector shallorder the return of the guarantee on application by the guarantor.
In the event of the circumstances referred to in Article 6(2) of Regulation No 1013/2006 arising, and if the notifier or the consignee has not complied with theobligations regarding, respectively, the appropriatereturn of the waste to the country of dispatch or the management of the waste on the territory of the country of destination, as laid down in the decisions referred to in Articles 24 or 26, the Chief Environmental Protection Inspector shall order, by way of a decision, that funds be allocated for such purpose from the financial guarantee in the amount necessary to meet said obligations.
Article 55 / Information on any customs offices designated by Member States for shipments of waste entering and leaving the Community
Has there been any designation? YESNo
(please tick as appropriate) √
If yes, please complete Table 6.
Note for completion of the tables:
D-codes and R-codes are those referred to in Annexes II A and II B to Directive 2006/12/EC.
Waste identification codes are those referred to in Annexes III, IIIA, IIIB, IV i IVA to this Regulation.
1
Table 1
INFORMATION ON EXCEPTIONS TO THE IMPLEMENTATION OF THE PRINCIPLES OF PROXIMITY,
PRIORITY FOR RECOVERY AND SELF-SUFFICIENCY (Article11(3))
Waste identification code / Quantity(Mg/m3) / Country of destination (De)/
country of dispatch (Di) / Disposal operation
D-code / Referral of the matter to the Commission
(Yes/No)
NOT APPLICABLE
1
Table 2
OBJECTIONS TO PLANNED SHIPMENTS OR DISPOSAL (Article 11(1)(g))
Waste identification code / Quantity(Mg/m3) / Country of transit(T)/
country of dispatch(Di) / Reasons for the objection
(please tick as appropriate) / Facility
Article
11(1)(g)(i) / Article11
(1)(g)(ii) / Article
11(1)(g)(iii) / Name(in case of Article 11(1)(g)(ii)) / Disposal operation
D-code
191210 / 2500 / DE / √ / - / - / - / R1*
* applied on the basis of Article 63(2)Regulation No 1013/2006 on shipments of waste
Table 3
OBJECTIONS TO PLANNED SHIPMENTS OR RECOVERY (Article 12(1)(c))
Waste identification code / Quantity(Mg/m3) / Country of destination / Reasons for objection
and details of relevant national legislation / Facility
(in the country of destination)
Name / Recovery operation R-code
PL000144
A3020* / 2000 / DE / PURALUBE GmbH Hauptstr. 30; 06729 Elsteraue OT Alttröglitz GERMANY / R9
PL000146
A3020* / 4000 / DE / MINERALÖL RAFFINERIE DOLLBERGEN GmbH Bahnhofstr. 82; 31311 Uetze-Dollbergen GERMANY / R9
PL000153
A3020* / 10000 / DE / MINERALÖL RAFFINERIE DOLLBERGEN GmbH Bahnhofstr. 82; 31311 Uetze-Dollbergen / R9
* the objections were set aside on appeal;by a decision issued in the second instance, a waste export permit was granted
1
Table 4
INFORMATION ON DECISIONS BY COMPETENT AUTHORITIES TO ISSUE PRE-CONSENTS (ARTICLE 14)
Competent authority / Recovery facility / Waste identification code / Period of validity / Total quantity of waste covered by pre-consentName and No of recovery facility / Address / Recovery operation+ R code) / Technology employed / Code / From / To / Tonnes(Mg)
Chief Environmental Protection Inspector / Zakład MetalCo Sp. z o.o. / ul. Chorzowska 109, Świętochłowice-Lipiny / R4 / Metal-melting process / B1010 170404 / 07.12.2007 / 07.12.2017 / 5 500 Mg/year
PL0001 / B1100 110502 / 1 500 Mg/year
Chief Environmental Protection Inspector / CMC Zawiercie S.A. / ul. Piłsudskiego 82, 42-400 Zawiercie / R4 / Metal-melting process / B1010 170405 / 17.12.2007 / 22.09.2017 / 800 000 Mg/year
B1010 191202 / 250 000 Mg/year
PL0002 / B1010 120101 / 190 000 Mg/year
Chief Environmental Protection Inspector / Alumetal S.A. / ul. Kościuszki 111,
32-650 Kęty / R4 / Metal-melting process / B1010 170402 / 05.02.2008 / 31.01.2018 / 35 000 Mg/year
B1010 120103 / 10 000 Mg/year
B1010 191002 / 4 000 Mg/year
B1010 170401 / 1 800 Mg/year
PL0003 / B1010 150104 / 500 Mg/year
Chief Environmental Protection Inspector / Zakład Produkcyjny BOLMET S.A. / ul. Przemysłowa 5, Wiechlice / R4 / Metal-melting process / B1100 110501 / 20.12.2007 / 13.12.2017 / 1 200 Mg/year
B1020 170403 / 6 900 Mg/year
PL0004 / B1010 170404 / 8 040 Mg/year
B1010 170402 / 3 000 Mg/year
Chief Environmental Protection Inspector / Alumetal Gorzyce Sp. z o.o. / ul. Odlewników 52, 39-432 Gorzyce / R4 / Metal-melting process / B1010 170402 / 05.02.2008 / 31.01.2018 / 8 000 Mg/year
B1100 120103 / 4 000 Mg/year
PL0005 / B1010 170401 / 800 Mg/year
Chief Environmental Protection Inspector / Polska Wytwórnia Papierów Wartościowych S.A. / ul. Romana Sanguszki 1, 00-222 Warszawa / R3 / Used for production of banknote paper / B3030 040221 / 04.01.2008 / 31.12.2017 / 1 200 Mg/year
PL0006
Chief Environmental Protection Inspector / Mondi Świecie S.A.
PL0007 / ul. Bydgoska 1 86-100 Świecie / R3 / Wastepaper recycling process / B3020 030308 / 04.02.2008 / 31.01.2018 / 80 000 Mg/year
B3020 150101 / 200 000 Mg/year
B3020 191201 / 120 000 Mg/year
B3020 200101 / 50 000 Mg/year
Chief Environmental Protection Inspector / Orzeł Biały S.A.
PL0008 / ul. Roździeńskiego 24Piekary Śląskie / R4 / Battery recycling process / A1160 160601* / 03.03.2008 / 12.02.2018 / 24 000 Mg/year
A1160 191211* / 10 000 Mg/year
Metal-melting process / B1010 170403 / 12 000 Mg/year
Chief Environmental Protection Inspector / HUTMEN S. A.
PL0009 / ul. Grabiszyńska 241 53-234 Wrocław / R4 / Metal-melting process / B1010 170401 / 03.03.2008 / 28.02.2008 / 4 000 Mg/year
Chief Environmental Protection Inspector / PPHU IRPOL Irena Śliczna
PL0010 / ul. Bolesławiecka 26 59-707 Trzebień / R3 / Clothing recycling proces / B3030 200110 / 03.03.2008 / 26.02.2018 / 4 950 Mg/year
B3030 200111
Chief Environmental Protection Inspector / FABRYKA PAPIERU Sp. z o.o.
PL0011 / Dąbrowica, 58-500 Jelenia Góra / R3 / Wastepaper recycling process / B3020 030308 / 12.03.2008 / 12.03.2018 / 1 500 Mg/year
B3020 030399 / 300 Mg/year
B3020 150101 / 1 500 Mg/year
B3020 191201 / 700 Mg/year
Chief Environmental Protection Inspector / CEMEX POLSKA Sp. z o.o, Zakład Cementownia Chełm / ul. Fabryczna 6, 22-100 Chełm / R5 / Recovery of inorganic materials / B1210 100201 / 21.03.2008 / 17.03.2018 / 1 000 Mg/year
PL0012
Chief Environmental Protection Inspector / CEMEX POLSKA Sp. z o.o, Zakład Cementownia Rudniki
PL0013 / ul. Mstowska 10, 42-240 Rudniki / R5 / Recovery of inorganic materials / B1210 100201 / 31.03.2008 / 31.03.2018 / 845 000 Mg/year
Chief Environmental Protection Inspector / GÓRAŻDŻE CEMENT S.A.
PL0014 / Chorula
ul.Cementowa 1
45-076 Opole / R1 / Incineration with energy recovery / B3010 020104 / 28.03.2008 / 25.03.2018 / 35 000 Mg/year
B3010 070213
B3010 120105
B3010 150102
B3010 160119
B3010 170203
B3010 200139
B3010
B3040 191204
B3140 160103 / 22 000 Mg/year
not on list 191210 / 122 000 Mg/yearin 2008
105 000 Mg/year in 2009
87 000 Mg/year in the years 2010 - 2018
Chief Environmental Protection Inspector / BORYSZEW S.A. Oddział ELANA / ul. M. Skłodowskiej - Curie 73, 87-100 Toruń / R3 / Recovery of organic substances / B3010 070213 / 01.04.2008 / 30.03.2018 / 3 000 Mg/year
B3010 070299 / 3 000 Mg/year
PL0015 / B3010 150102 / 15 000 Mg/year
Chief Environmental Protection Inspector / ROCKWOOL Polska Sp. z o.o.
PL0018 [0-30mm] / ul. Kwiatowa 14; 66-131 Cigacice / R5 / Recovery of inorganic materials / B1210 100201 / 30.06.2008 / 30.06.2018 / 80 000 Mg/year
Chief Environmental Protection Inspector / WALCOWNIA METALI DZIEDZICE S.A.
PL0019 / ul. Kaniowska 1; 43-502 Czechowice-Dziedzice / R4 / Metal-melting process / B1010 120113 / 12.09.2008 / 29.06.2018 / 80 Mg/year
B1010 120104 / 80 Mg/year
B1010 160118 / 200 Mg/year
B1010 170401 / 2 000 Mg/year
B1010 170402 / 20 Mg/year
B1010 170403 / 90 Mg/year
B1010 170404 / 90 Mg/year
B1010 170406 / 100 Mg/year
B1010 170407 / 50 Mg/year
B1010 170411 / 50 Mg/year
B1010 191002 / 100 Mg/year
B1010 191203 / 200 Mg/year
Chief Environmental Protection Inspector / WALCOWNIA METALI DZIEDZICE S.A.
PL0020 / ul. Hutnicza 13; 43-502 Czechowice-Dziedzice / R4 / Metal-melting process / B1010 120113 / 12.09.2008 / 29.06.2018 / 20 Mg/year
B1010 120104 / 20 Mg/year
B1010 160118 / 200 Mg/year
B1010 170401 / 1 000 Mg/year
B1010 170402 / 80 Mg/year
B1010 170403 / 10 Mg/year
B1010 170404 / 10 Mg/year
B1010 170406 / 100 Mg/year
B1010 170407 / 50 Mg/year
B1010 170411 / 50 Mg/year
B1010 191002 / 100 Mg/year
B1010 191203 / 200 Mg/year
Chief Environmental Protection Inspector / ROCKWOOL Polska Sp. z o.o.
PL0018 [60-1500mm] / ul. Kwiatowa 14; 66-131 Cigacice / R5 / Recovery of inorganic materials / B1210 100201 / 30.06.2008 / 30.06.2018 / 80 000 Mg/year
Chief Environmental Protection Inspector / KOBRA Sp.j. Teresa Olejnik i Mirosław Hamerliński
PL0022 / ul. Męczenników Oświęcimskich 1; 68-200 Żary / R3 / Recovery of organic substances / B3030 200110 / 18.08.2008 / 29.07.2018 / 6 500 Mg/year
B3030 200111
Chief Environmental Protection Inspector / Ferrostal Łabędy Sp.z.o.o. Stalownia
PL0023 / ul. Zawadzkiego 45, 44-109 Gliwice / R4 / Metal-melting process / B1010 020110 / 20.10.2008 / 30.09.2018 / 5 000 Mg/year
B1010 100299 / 40 000 Mg/year
B1010 120101 / 50 000 Mg/year
B1010 120102 / 30 000 Mg/year
B1010 120199 / 40 000 Mg/year
B1010 150104 / 30000Mg/year
B1010 160117 / 40 000 Mg/year
B1010 160216 / 20 000 Mg/year
B1010 160304 / 30 000 Mg/year
B1010 170405 / 410 000 Mg/year
B1010 190102 / 10 000 Mg/year
B1010 191001 / 30 000 Mg/year
B1010 1912 02 / 70 000 Mg/year
1
Table 5
INFORMATION ON ILLEGAL SHIPMENTS OF WASTE[*] (Article 24 andArticle 50(1))
Waste identification code / Quantity(Mg/m3) / Country of destination (De) and country of dispatch (Di) / Identification of the reason for illegality
(possible reference to violated Articles) / Responsible for illegality
(please tick as appropriate) / Measures taken including possible penalties
Notifier / Consignee / Other
Cases concerning illegal shipments initiated in the years 2006-2007, closed in 2008 r.
191212 / 2753 / Germany (Di)
Poland (De) / Article 2(35) of Regulation No 1013/2006 on shipments of waste
a) without notification to all competent authorities concerned / √ / - / - / Importation took place in 2006;the waste was partially returned to the country of dispatch in 2008; a quantity of around 500 Mg remained to be repatriated
191212 / 500 / Germany (Di)
Poland (De) / Article 2(35) of Regulation No 1013/2006 on shipments of waste
a) without notification to all competent authorities concerned / √ / - / - / Importation took place in 2006;the waste was returned to the country of dispatch in 2008.
191212 / 260 / Germany (Di)
Poland (De) / Article 2(35) of Regulation No 1013/2006 on shipments of waste
a) without notification to all competent authorities concerned / √ / - / - / Importation took place in 2007;the waste was returned to the country of dispatch in 2008.
Cases concerning illegal shipments of waste initiated and closed in2008.
B3010 / 3.8 / Slovakia (Di)
Poland (De) / Art. 2(35) of Regulation No 1013/2006 on shipments of waste
a) without notification to all competent authorities concerned / √ / - / - / Waste returned to country of dispatch.
200301 / 67.82 / Germany (Di)
Poland (De) / Article 2(35) of RegulationNo 1013/2006 on shipments of waste
d) in a way which is not specified materially in the notification or movement documents
Importation of municipal waste under pretence ofmaking a waste shipment notification concerning construction waste of specified composition / √ / - / - / Waste returned to country of dispatch.
200301 / 20.56 / Germany (Di)
Poland (De) / Article 2(35) of Regulation No 1013/2006 on shipments of waste
d) in a way which is not specified materially in the notification or movement documents
Importation of municipal waste under pretence of making a waste shipment notification concerning construction waste of specified composition / √ / - / - / Waste returned to country of dispatch
B2020 / 145.29 / Switzerland (Di)
Poland (De) / Article 2(35) of Regulation No 1013/2006 on shipments of waste