While amendments to the National Environmental Waste Management Act include the Waste Classification and Management Regulations (WCMR), environmental consultancy GreenGain Consulting believes that various companies have not yet amended their management procedures to ensure that WCMR obligations are incorporated to ensure compliance with the Act.
GreenGain Consulting health, safety and environmental legal practitioner Liezl Sterne tells Engineering News that compliance might be difficult to achieve because there are sections in the WCMR regarding waste classification that have to be clarified.
“However, in terms of managing waste, the regulations are fairly straightforward and easy to comply with.”
Nevertheless, Sterne acknowledges that companies’ greatest challenge currently is to remain informed of the constant amendments being made to existing legislation and new legislation being promulgated. This challenge increases significantly when companies do not have legal or environmental advisers to interpret their obligations, while a lack of in-house capacity could exacerbate the difficulties of implementing management systems to ensure compliance.
She suggests that the first step towards ensuring compliance is aligning documented procedures with the required obligations and implementing systems to ensure proper record keeping. She also recommends that companies communicate procedural changes and train their employees to familiarise them with waste management protocol.
Promulgated in August 2013, the WCMR require waste-generator companies to classify their waste within 180 days of generation using either the list of preclassified wastes in Annexure 1 of the WCMR or SANS 10234, instead of the Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste that was replaced by the WCMR.
Following the classification process, waste-generator companies must ensure that waste is assessed in accordance with the Department of Environmental Management’s Norms and Standards for Assessment of Waste for Landfill Disposal before disposing of the waste to landfill.
Further, the disposal to landfill must also be done in accordance with the Norms and Standards for Disposal of Waste to Landfill.
Meanwhile, Sterne notes that waste-generator companies must ensure that their waste is reused, recycled, recovered, treated and/or disposed of within 18 months of generation.
She points out that the WCMR also stipulate specific management obligations for waste storage, transportation and disposal. In terms of the regulations, waste-generator companies must keep accurate and updated records of their hazardous-waste management protocol for at least five years.
“GreenGain Consulting, therefore, strives to provide companies with the tools they need to simplify their management systems. The tools and services we offer are aligned with both new legislation and the latest trends in the marketplace,” explains Sterne.
GreenGain’s health, safety, environmental and quality management system software, Digilex, provides clients with a monthly update letter regarding any legislative changes.
Companies should use these updates to identify applicable changes and update their systems to promote compliance and proactively ensure the integration of the new legislation into their management systems, Sterne suggests.
Digilex further provides customised legal registers compiled to not only identify applicable legislation but also provide a layman’s interpretation of the legislation and relevant sections detailing the requirements for waste management compliance.
Other Digilex modules are designed to assist companies in effective management of their systems by incorporating tools, such as Legal Audits, which enables the client to conduct in-house legal audits, based on applicable legislation, to determine compliance and implement corrective actions.