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How should China manage its 45,000 hazardous waste types in a refined way?
Release time:
04 Dec,2015
Some provisions of China's Law on the Prevention and Control of Environmental Pollution by Solid Waste and its supporting regulations and management requirements are vague, inapplicable, or even have gaps; some have been distorted in their implementation, becoming blind spots and bottlenecks in hazardous waste management. In view of the problems existing in hazardous waste management, this article puts forward the following suggestions:
Some provisions of China's "Law on the Prevention and Control of Environmental Pollution by Solid Waste" and its supporting regulations and management requirements are vague, inapplicable, or even have gaps; some have been distorted in implementation, temporarily becoming blind spots and bottlenecks in hazardous waste management. In view of the problems existing in hazardous waste management, this article puts forward the following suggestions:
Hazardous waste has become an important regulatory object
Statistics show that China currently produces and uses 45,000 kinds of chemical substances, of which at least 2500-2900 are toxic and harmful chemicals. According to data released by the Ministry of Environmental Protection, in 2013, the total amount of industrial hazardous waste generated in 261 large and medium-sized cities nationwide was 29.3705 million tons, and the amount of medical waste generated was about 547,500 tons.
Large quantities, multiple categories, and complex components are the difficulties in hazardous waste management, while inadequate awareness, lack of institutions, and insufficient capacity are the weaknesses in hazardous waste management. In recent years, significant progress has been made in the standardized management of hazardous waste, but the overall situation is still relatively extensive.
1. Establish the legality of electronic archives
The "Measures for the Management of Hazardous Waste Transfer Consignment Notes" stipulates a five-part consignment note system for hazardous waste transfer, with clear requirements for filling out, delivery, and archiving of consignment notes. With the rapid development of environmental protection information management, many places have implemented information management methods such as electronic consignment notes, electronic accounts, and electronic archives. Therefore, it is necessary to quickly seamlessly integrate electronic information management with current relevant laws, regulations, management requirements, and technical means to free up regulatory resources and improve regulatory efficiency.
2. Clarify the scope of hazardous waste for harmless treatment
The "National Hazardous Waste Catalog" stipulates that "hazardous waste polluting soil generated by sudden pollution accidents", identified as hazardous waste, shall be managed in accordance with the hazardous waste management regulations. However, some practical problems in the work still need further consideration. For example, highly polluted soil generated by soil remediation projects may be hazardous. However, the amount of such highly polluted soil is huge, and if it is managed as hazardous waste, local governments do not have the capacity to properly store, transport, and dispose of it in a timely manner. For example, waste acid, waste activated carbon, and waste catalysts produced by some enterprises have recycling value. If all of them are required to be harmlessly treated, it will be a huge waste of resources. The priority principle of China's hazardous waste pollution prevention and control technology policy is reduction, resource utilization, and harmless treatment. Therefore, it is necessary to define a reasonable scope for which hazardous wastes truly need to be harmlessly treated as hazardous waste, and to implement classified disposal and management of hazardous waste.
3. Adjust the control scope of cross-regional transfer
Article 59 of the "Solid Waste Law" stipulates that the transfer of hazardous waste across cities requires approval from the municipal environmental protection departments of both the transfer-out and receiving areas. Some local regulations have stricter requirements. For example, the "Jiangsu Provincial Regulations on the Prevention and Control of Environmental Pollution by Solid Waste" stipulates that the transfer of hazardous waste across county (city) administrative regions shall be subject to hazardous waste transfer approval procedures. In reality, given the scarcity of hazardous waste disposal resources, few county (city) administrative regions can fully meet the disposal needs of local waste-generating enterprises. Cross-regional disposal is usually required. Currently, most places can effectively control the transfer of hazardous waste within prefecture-level cities, or even within the province. Therefore, appropriately adjusting the approval scope for hazardous waste transfer, delegating approval authority, and simplifying approval procedures can significantly improve transfer efficiency and reduce management costs.
4. Distinguish between unlicensed operations and comprehensive utilization
According to relevant regulations such as the "Environmental Protection Law" and the "Solid Waste Law", units engaged in the collection, storage, and disposal of hazardous waste must obtain a hazardous waste operation license. The application conditions and related approval procedures are relatively strict. Some wastes with high recycling value, such as catalysts and ash containing precious metals, cannot realize their recycling value if they are treated as hazardous waste. The author believes that if some hazardous waste can be used as by-products by other enterprises without affecting the environment and the environmental risks are within a controllable range, it can be considered to break away from the restrictions of licensed operations. For example, sludge from industrial wastewater treatment facilities that can be sold to other enterprises as inoculum sludge falls into this category.
5. Grasp the scale of standardized management
Standardized management of hazardous waste should grasp the scale and implement it flexibly. For example, hazardous waste storage exceeding one year must be reported for approval. However, some enterprises may only generate a few kilograms of hazardous waste each year, and disposal and transportation units are unwilling to accept it. Some enterprises, in order to avoid the trouble of reporting for approval, illegally dispose of it mixed with other waste.
6. Solve the problems of "not enough to eat" and "unable to eat"
Local governments should unify the planning, guidance, and investment in hazardous waste disposal resources to make up for the blindness and lag of the market. At the same time, they should strengthen regional coordination and linkage in hazardous waste management to reduce the phenomenon of excessive use or idle waste of regional hazardous waste disposal resources, and achieve resource sharing and mutual benefit. Many hazardous waste enterprises have poor facility quality, short service life, high equipment replacement and repair frequency, and abnormal facility operation, resulting in a discount on the designed hazardous waste disposal capacity in the region.
7. Improve the efficiency of hazardous waste identification
The "two high" judicial interpretation issued in 2013 defines the illegal disposal of more than 3 tons of hazardous waste as a crime of polluting the environment, and hazardous waste identification has become an important basis for filing a case. Currently, hazardous waste identification faces the problems of high cost and long time. Therefore, some places, after investigating illegal dumping of solid waste, may not be able to conduct timely investigations due to the inability to implement identification funds, or the judicial authorities may not file a case due to the lack of hazardous waste identification conclusions. To this end, it is necessary to strengthen the construction of hazardous waste identification institutions, establish a hazardous identification fund, and at the same time, improve practicality and operability by simplifying procedures, reducing costs, and developing rapid technologies, so as to better serve hazardous waste management.
Source: China Environmental News
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