President's Blog

27 May 2019 11:29 Age: 22 days

GUEST BLOG | Hazardous Waste Management in the context of Circular Economy - An Holistic Approach

Category: ISWA BLOG


On May 21 in Osaka, Japan, a workshop organized by UNEP IETC focused on Hazardous Waste Management in the context of Circular Economy. At this workshop ISWA was represented by Nicolas Humez, Chair of ISWA’s Working Group on Hazardous Waste and Directeur des Relations Institutionnelles of SARP Industries. Below is Nicolas' contribution to the fruitful discussion which involved different public and private sector international stakeholders.

Nowadays when one is talking about waste management, including hazardous waste management, it immediately falls down into circular economy. This year, the 4th assembly of the UN Environment took very strong resolutions regarding circular economy and the chemical and waste issue. At the same time, the publication of the Global Chemical Outlook II (GCO II) pointed out the need for urgent actions in order to tackle chemical pollution as global production is set to double by 2030. More and more chemicals, more and more products containing high concentration of chemicals, this means also more and more hazardous waste which pop up consequently at the core of the worries. The hazardous waste management sector has to take its responsibilities in order to provide the right solutions ensuring safe treatment and that unwanted chemicals are efficiently extracted from the material loops.


Thus, we face big challenges!


The first one shows how schizophrenic our society is. On one hand, nobody can contest that chemicals are necessary and are present everywhere in our daily life. But, on the other hand, chemicals jeopardize our health, the quality of our indoor air, of our water bodies and of recycling.

Regarding the last issue, how can we balance between ambitious recycling targets and protection of human health and the environment? Recycling targets have not been assessed taking into account the potential content of substances of concern that mustn't come back into the material loops. Are trade-offs acceptable? This is the second challenge.


And finally, the list of substances of concern (substances of very high concern - SVHC - from REACh, POPs, endocrine disrupting chemicals and others) steadily grows. It addresses two issues: the presence of legacy substances in a lot of end-of-life products and how to make the information available along the value chain until the waste operators. This third challenge is very well illustrated with plastics. The GCO II emphasized, on one hand, that the plastic demand will increase exponentially by 2050. On the other hand, it also shows that plastic is the category of products where the number of substances of very high concern is among the highest. What will be the impact of recycling if we do agree that ambitious recycling targets should not be set and reached at the expense of human health and the environment?


So, are there proposals to solve the difficult equation of improving recycling and, at the same time, preserving health and environment?


Among others, when it comes to hazardous waste, it is essential to clarify the interface between chemicals, products and waste legislations. The uses of chemicals in products is well defined while the fate of the waste is unpredictable. Consequently, a waste can only be classified on its intrinsic properties, it is the hazard-based approach. Declassify a waste by circumventing the hazardous based approach taking the excuse that otherwise it would hamper recycling is not acceptable. Diluting waste containing high concentration of substances of concern with other waste in order to comply with specific thresholds is not an option if we want to get rid of those substances of concern and pave the way towards a toxic-free environment. Shouldn’t we shift from quantitative recycling target to qualitative recycling targets? For that, traceability, non-dilution and decontamination are key.


The hazardous waste management sector has also its role to play. It should assess or reassess its impact ensuring the right balance on three pillars:


● climate change mitigation,
● health protection,
● resources saving (as a user and as a provider).


It will certainly imply changes in processes and waste-to-chemical will develop more and more as it is the best way to decontaminate and recover the valuable materials.
We should not forget the role of Society. But let's start by basic principles before.


First of all, recycling is not sufficient to achieve circular economy. The graph (above) illustrates the part recycling represents compared to the demand on a specific resource. Without any change in our consumption model, extraction of natural resource will remain too intensive.


Secondly, Innovation and efficiency should be regarded carefully. Indeed, in our current economic model, the evolution in technologies leads to accumulation instead of replacement and efficiency can lead to more consumption and emissions due to the rebound effect.


Finally, it is easy to understand that the role of society is fundamental. One part of the actions is on the shoulders of the policymakers. A real engagement in dis-accumulation (shifting from an additive to a replacement system) is key. Probably a worldwide development of the carbon tax will foster disinvestment in fossils and also incentivise recycling due to the embedded cost in products.


The second part of the job is for all of us. We have to rethink our relationship to production and consumption and try to move towards sobriety. A chosen and happy sobriety today is much more enthusiastic than an imposed sobriety tomorrow! Probably a product hierarchy would help prioritizing between what is very necessary, what is necessary and what is not necessary. A 3 “N” hierarchy on products would echo the 3 “R” hierarchy on waste.


To conclude, today, we know what are the consequences of our current model and if we believe in what we know, we don't have any other choice than act consequently.