memorandum
to:Ibrahim Shafii, SBC
from:Mike Harris, member of the Intersessional WG on POPs Waste GUIDELINES
subject:Comments on Draft PCB Waste Guidelines
date:06 June 2004
cc:Pierre Portas (SBC)
Use of ‘Fact Sheets’ in Guideline on Pesticide Wastes
Comments on 2 June 2004 e-mail from I Shafii
On behalf of the chemical and crop protection industries, I submit the following comments as a member of the small intersessional working group acting under the auspices of the Technical Working Group of the Basel Convention. The comments relate to the proposal regarding the use of ‘fact sheets’ in the e-mail dated 2 June 2004 from I Shafii (SBC).
We appreciate the opportunity to make these comments and look forward to seeing an improved draft Table of Contents in the near future.
Mike Harris, for the World Chlorine Council
WCC opposes the use of ‘fact sheets’ as proposed, for the following reasons:
1.The intersessional working group and the OEWG have already agreed a structure and content for the general guideline and for one daughter guideline (PCB). It would be inappropriate to adopt an entirely different approach for another daughter guideline (pesticide POPs) unless there were an overwhelming reason to do so – in which case, the new structure should be approved not only by the intersessional working group but also by the OEWG (as we would be proceeding against their agreed advice).
2.If we were to adopt fact sheets for the pesticide POP guideline we would be obliged to do likewise for the PCB and, particularly, for the general guideline. It is, after all, the latter that is supposed to focus most closely on the individual technologies – with the daughter guidelines referencing the general one and concentrating on the specific differences for each set of specific POPs wastes and on the applicability of each technology to these specific wastes. Any attempt to adopt fact sheets for the general and PCB guidelines is likely to ensure that these guidelines will not be agree in time for the Basel and Stockholm COPs, as had been hoped and planned.
3.Adding fact sheets would considerably increase the length of the guideline. At one stage the intersessional working group agreed a target length of 20 pages or so. We are already at 60+ pages even without fact sheets!
4.Fact sheets are not necessary for the guidelines to achieve their purpose, i.e. providing guidance on how to manage the subject wastes in an environmentally sound manner, including an agreed critical review of those technologies and methodologies that might be appropriate. No one is going to actually proceed with a project on the basis of the guidelines alone. Much more information would be required before major commitments and investments are made. The guidelines can usefully point in the right direction by providing references to information sources, but fact sheets are both too much (for the guidelines) and too little (for deciding on a project or an investment).
5.Any fact sheets included in the guideline would ipso facto carry the authority of the bodies of the Basel Convention. Therefore, any fact sheets included would have to be studied, critically reviewed and validated by the intersessional working group before any draft could be proposed to the OEWG (who in turn would have to study and approve before submission to the COP for final approval). It is doubtful whether the intersessional working group (and even less so the OEWG) has sufficient time (or possibly even sufficient expertise) to make these judgements. It would be entirely inappropriate and irresponsible simply to adopt a fact sheet from some other source without being sure that it was a balanced and representative summary of the technology proposed. As existing fact sheets are almost without exception generated by promoters and/or purveyors of particular technologies – or closely based on information from these sources – they are unlikely to represent a completely neutral and unbiased analysis of the technology options. The Basel Convention is not an agent of the technology provider.
6.The Internet provides several examples of fact sheets on several of the newer non-combustion technologies – unsurprisingly as these new and innovative technologies are competing for their share of the waste disposal market. These technologies are also often provided by a single supplier, or at most two or three suppliers, who understandably prepare fact sheets to introduce potential customers to their new technologies. On the other hand, we have yet to find a similar summary fact sheet on any of the combustion technologies (e.g. high temperature incineration). This is also unsurprising as these technologies are well-established, with numerous suppliers, and the potential customer is likely to by-pass the “fact-sheet stage” and enter into direct discussion with one or more potential bidders for a possible contract – with all parties already broadly familiar with the technology to the level that could be provided in a ‘fact sheet’. As it would be inappropriate to provide fact sheets for some but not all of the technologies, it would be necessary to generate ‘fact sheets’ for the combustion technologies. Should this be a single fact sheet for ‘high temperature incineration’, or a separate one of each of its many different technical variants – rotary kiln, fluid bed, etc. etc.?
Further points related to the specific fact sheets provided by way of example (GPCR)
It is stressed that the following comments in no way reflect on GPCR as a technology, but on the particular fact sheet provided and the concept of such fact sheets being used in Basel Convention guidelines.
7.The fact sheet provided is taken verbatim from the annexe to the GEF-STAP report on a workshop on non-combustion technologies.
While this may reduce work for the consultant (who we understand prepared some of the annexes for GEF-STAP), does it mean that the Basel Convention automatically and uncritically accepts everything in the GEF-STAP report (including its annexes)? As Greenpeace[1] have correctly said in their earlier comments on the general POP guideline “… the GEF review does not recommend technologies, it categorizes technologies based on their capabilities and stage of development.”
8.The same fact sheet is also to be found verbatim on the Greenpeace web site at
Again, while Greenpeace is fully entitled to take a view and to recommend this technology and thus this vendor, we could only do so after a full and proper analysis of the claims in the fact sheet – preferably using independent sources.
9.The material in the fact sheet is also to be found in detail (and with supporting documentation) on the manufacturer’s web site:
10.Even the file providing the sample GPCR fact sheet is labelled with the technology vendor’s name – highlighting the problem of producing a neutral technical fact sheet on a new technology having a single supplier without appearing to underwrite and approve the supplier as well as the technology. This would be very risky for the credibility of the Basel Convention bodies.
11.We have been able to find fact sheets in very similar format on some of the other non-combustion technologies on various web sites – including those dedicated to the study and promotion of “non-combustion technologies”. A good example is the above-mentioned GEF-STAP report from a workshop in October 2003 correctly and unequivocally titled “POPs Workshop on Emerging Innovative Technologies for the Destruction and Decontamination of Obsolete POPs” (emphasis added). But we have been unable to find similar fact sheets on combustion technologies. While the new non-combustion technologies are in some cases very promising and beginning to prove their worth as alternatives, it is not our task to promote either “combustion” or “non-combustion” approaches, but rather to provide a brief critical summary of the various technologies (of whatever kind) that may be appropriate for the environmentally sound management of POPs wastes. It would not be possible to agree to the concept of fact sheets without seeing the full range – including the combustion technologies – and having the opportunity to evaluate the texts. This would be a major task, probably beyond the time and technical resources of the present intersessional working group.
WCC therefore proposes that:
oFact sheets should not be incorporated in the guidelines.
oReferences to fact sheets and similar material should be provided in the appropriate Annexe of the guidelines so that readers can follow up their interests in particular technologies by reference to manufacturers’, vendors’ and protagonists’ materials. Readers can then make their own assessment of the source materials, in the light of the more general comparative analysis provided in the Basel Convention Guidelines, and also contact vendors if they wish to go into more detail than a mere fact sheet can provide.
WCC Comments on Fact Sheet Proposal, June 2004FINAL – 06 June 2004Page 1 of 3
[1] Pat Costner, 1 April 2004, written comments on 22 February 2004 draft of the general POP guideline.