Planning of hazardous waste disposal, how not to get stuck with your waste

In many cases waste disposal is considered by the end of a project when the waste comes available and that is too late.

Why wait?
Why don’t people look at the waste disposal aspects earlier in a project? Reasons can be that the quantity is not known yet or that the composition of the waste is not known. Due to the unknown composition it may not be possible to establish the hazards. In some cases the project resulting in the waste is done by an industrial services contractor and at the end of the project the waste is handed to the owner or operator of the plant. Waste disposal may be the responsibility of another part of the organisation that is not involved in for example maintenance projects. Or waste disposal is simply underestimated.

Integrate waste disposal
With most waste, but certainly when dealing with hazardous waste it pays off to consider disposal as early as possible in the project and integrate it in the planning. Not doing so can lead to serious delays and long times of getting stuck with waste. Many countries also limit the time that you can store waste leading to possible violations if you can’t move it in time.

Dispose, treat or recycle
Depending on your waste stream it may be complex to get rid of and the more hazardous the fewer options you may have. Knowing your disposal options is an important step. Can you simple dispose, is treatment required or is it possible to recover materials that can be recycled? Is the solution nearby or far away? Advanced treatment and recycling facilities are often located in western countries. One of the reasons for this is that it is illegal under the UN Basel convention to move hazardous waste in to a developing country. Therefore waste treatment facilities in developing countries can only cater for the domestic market making it difficult to reach sufficient economy of scale.

Another good reason to plan ahead is packaging having the right packaging from the start saves repacking when the waste can’t be moved if packed wrong. Packaging of waste is regulated and important for the safety of transport, storage and handling. Sometimes suitable packaging is not locally available and needs to be imported. Limiting the time the waste is packed can also lead to savings, under some conditions, rain, moisture and sunlight packaging can deteriorate very fast and it is not uncommon that repacking is required prior to transport after long periods of storage.

When waste has to be stored and moved permits will be necessary. Obtaining permits can take a lot of time as you have to work with governmental organisations. When waste has to be moved between countries permission is needed not only from the country of origin and the destination country, but from every intermediate country that the transport passes trough. Even when waste stays on board of a ship visiting a port the authorities of that country have to give permission for the waste to be on board. This system of permitting is regulated under the UN Basel convention. Obtaining all the permissions can take more than half a year depending on the countries involved. Some countries also require inland waste movement permits and special licenses and insurances for the vehicles used for the transport. Storage facilities need to be licensed for the storage of the waste and there may be limits to the time that waste can be stored. Regulatory frameworks differ by country. All issues that take time to clear if you want to make sure you stay within the rules.

Transport and storage
Pending the permits transport has to be organised and that is also not easy. Many transport companies, shipping lines in particular, don’t like waste on board their vessels. Most simply refuse all waste and by doing so they make it even harder to find proper disposal solutions for complex hazardous waste. Some shipping lines do accept waste under strict conditions and only via specialized booking agents that work with experienced people in the field that know how to safely load and secure hazardous waste cargo. In all cases acceptance of the hazardous cargo is in the hands of the DG (Dangerous Goods) department of a shipping line and the final decision is with the captain of the vessel who can refuse cargo in exceptional cases. The hazardous cargo needs to be very well documented, not only in writing, often pictures of the cargo and it’s securing in the containers are required too.
Depending on the departure port temporary storage may be needed at the port between delivery of the cargo and loading it on the vessel. Also for this short term storage the warehouse needs to be licensed to store the waste.

Not including waste disposal in your project can cause serious delays and unexpected additional cost. Altogether a lot has to be planned and organised to timely and legally dispose of hazardous waste. If you need a helping hand, let me know!

Overfishing in the decommissioning market before it even kicks-off.

One of the hot topics in the oil & gas industry is decommissioning, the vast amounts of old platforms, pipes and other installations and equipment that needs to be dealt with. A golden opportunity for many and a possible bottomless pit for others.

Initially expected to kick off for 2015, now more like 2018, maybe even later.

Forecasts of the business volumes are going wild and many market developers are drooling by the looks of them and so are their bosses. But the market is still in the powerpoint phase.

Service and construction companies in the peripheral of oil & gas see it as the replacement of revenues lost due to the downfall in the industry but the oil & gas producers are not eager to start while their income is at an all time low.

Massive vessels and scrapyards are built by the big players in the market and also many of the smaller companies see a change to get a share of this huge cake.

The owners of the installations are procrastinating to say the least and in the mean time looking for all possible ways to reduce the cost or even prevent scrapping at the scale originally foreseen.

As a garbage man I’m often asked about the waste aspects of decommissioning, the hazardous, mercury waste in particular.

Some players see enormous streams of hazardous waste containing mercury and other elements and are looking at setting up local treatment installations to deal with it.

As far as I’m concerned we don’t even know what the waste stream will look like. Although it would be great to receive massive amounts of cleaning waste at our plant I really don’t think it will happen. Nor do I see many local contenders in the decommissioning being successful in setting up and running treatment facilities.

Right now there are a handful of mercury waste treatment plants like Batrec in the world and they seem to be able to cope with the existing waste streams and they all will confirm that it’s not easy to run such an operation dealing with highly toxic waste.

I fear a lot of environmental issues if in 5 years from now we will have a handful of mercury waste facilities in every country with a serious oil & gas industry.

In the mean time the influential lobby of the oil & gas industry is using the delay to find support for other, cheaper options to deal with the installations up for decommissioning. Who can tell? We may end up with a lot of artificial reefs, fish farms, naval bases or lunar observatories to mention a few silly options.

In short, the industry knew that there would come a time to take their installations away and that they are dirty, but nobody expected the oil price to be this low as it is now when it’s time to pack up.

Not as many installations will be scrapped in the way we anticipate now and the waste streams are hard to predict in both volume and composition.

Looking at the number of companies that is after a share of the decommissioning market the competition will be very fierce and as a result the margins will be thin. Too many fishing in the same market that didn’t even kicked-off.

Does the Basel convention really work? Or can we do better?

Or is it causing more hazardous waste to be disposed of illegally?

The Basel convention was initiated in 1989 to make sure hazardous waste would not end up being dumped in developing countries. It creates a framework of definitions, rules and cooperation between authorities regulating the transboundary movement of hazardous waste.

The Basel convention should make it easy to move waste to a proper disposal facility and difficult to move it anywhere else. But in practice it doesn’t always work out that way and many difficulties are encountered before hazardous waste can be moved to the right destination.

Following some examples of the hurdles that have to be taken based on almost a decade of moving hazardous waste.

Some definitions first; when we talk about waste we have a “waste generator” that is responsible for proper disposal of it’s waste and remains that under the Basel framework until the “disposal facility” signs of for final disposal. In every participating country there is an “authority” that is responsible for the execution of the Basel convention. And there are other involved parties providing services or executing other regulations like shipping lines, booking agents, consultants, trucking companies, railroads, customs, other local authorities, etc.

Some of the difficulties encountered

Waste generators often have no idea where to go with their waste due to lack of information. In many cases the presence of hazardous elements is ignored to avoid the issue and the cost. You can always ignore what you don’t measure or check and act surprised if caught. The best guarantee for proper waste disposal is the involvement of global operating companies with public traded shares. They can’t afford negative press and the potential effect on share prices is insignificant compared to the cost of responsible waste disposal.

Under the Basel framework you need permission from all involved authorities before you can start moving hazardous waste. The involved authorities are:

The country of origin
The application procedure starts with the authorities in the country of origin of the waste with the complete information package that can easily be over 100 pages of documents. In some countries the authorities have little or no knowledge about the procedure or try to exploit the occasion of a Basel waste movement application. As an example by demanding to audit the destination facility, whereas the destination facility is under responsibility of the authorities in the destination country and there is no reason under the Basel framework for them to audit this facility. It does however result in nice pictures on Facebook and considerable extra cost and wasted time for the waste generator. More issues can come from other local authorities that require additional permits to move waste inside the country and customs that have requirements that are often not in line with each other.

The country of transshipment, if applicable
Often there is no direct connection between the country of origin and destination. In such cases it’s necessary to plan a transshipment where the cargo moves from one vessel to another. The issues here are that different countries and sometimes different ports have different rules and demands. Some countries, like Singapore for example require a local agent and a security deposit. The maximum duration of the cargo being in the transshipment port differs per port and country, 3 days, 7 days, 10 days, hard to plan with shipping lines.

The countries that the shipment passes trough
This is when a ship is just visiting a port with your cargo on board.
All these authorities need to give permission, but some never react. Contact data not up to date, a revolution or civil war going on, mailbox full, staff changes, department moved, etc.
Some authorities require a payment, but don’t send an invoice. Some react only by email, but require information only by fax or postal service. Some react only by postal service, but don’t realize that it takes a month to reach the addressed. Some communicate only in their own language, not handy as not everybody reads German or Portuguese.

The country of disposal
In the destination country it’s not always clear what the responsible authority is. The Basel convention lists the national authority but in some countries part of the execution of the Basel convention is distributed to the province or state where the disposal facility is located and they are not mentioned anywhere. In general the country of disposal sends an invoice too, again often in their native language only and by postal service. You receive it when the payment term has passed, so a reminder with a fine follows with a term also before the arrival date.

All together a lot of difficulties before you have permission to start the actual process of moving waste. Time consumed in the application process is 3 months minimum to a year in some cases!

Than you get to work with the others

Shipping lines and logistic companies
Several incidents in the past years caused shipping lines and ship captains to become much more aware of their risks and liabilities. Some of these incidents involved hazardous waste and many shipping lines are refusing to transport waste by now. The ones that still accept have driven up the prices to insane levels and shipments can only be booked over a handful of specialized agents. Their local offices often have no experience with hazardous waste and the amount of people and departments involved, time and language differences, makes it very difficult to keep things under control.
Requirements for documentation, stowage and securing of the cargo, etc. are often changed per shipment and at last notice making it hard to meet deadlines.
I don’t go in details on land transport by truck or rail only by mentioning that even within the European Union there are 3 different regulations on how to secure cargo in a truck or container.

Hazardous waste is still ending up in wrong places!
Considering the amount of difficulties encountered in moving hazardous waste and the very few people that have enough knowledge and experience to complete the whole process it’s obvious that a lot of hazardous waste still ends up where it shouldn’t.

How to make it easier and assure that more waste is arriving at proper disposal facilities?

To the Basel convention organization my suggestions are:

Stronger coordination between the country authorities so that all have the knowledge, or access to it and all use the same rules and procedures. This should also include a reporting mechanism for discrepancies and methods of enforcement in case of violations of the rules.

Set up an automated system that facilitates the process of applying for permissions. In this system a waste generator or service provider logs on, provides the details of the intended waste movement, uploads files, etc. The system automatically dispatches the information to the authorities in the country of origin, transshipment countries and the destination country. The system tracks if the information is received and processed by all involved. In this way the contact data of all authorities is updated and registered in one place. This system could also clear payments of fees between the parties and possible also provide the security deposits. Once permission for the waste movement is granted the system can be used to transfer the required information between all parties until final disposal. The system will also provide accurate information about global waste movements and make it easier to spot discrepancies and changes.

Increase participation of other involved parties like shipping lines, specialized agents, service providers, consultants, waste generators, waste disposal facilities, etc. Possible this can evolve in a system of certified and trusted parties reducing the risks for all involved in handling and moving hazardous waste.

Initiate a whistle blower option where cases of mismanagement of waste can be reported if necessary anonymous. The environment is everyones responsibility and it shouldn’t be easy to mess with it.

Does the Basel convention really work?

Why ISO Systems don’t work in Thailand and probably most of Asia

A cultural mismatch.

Looking at all the companies in Thailand proudly presenting their ISO Certification(s) on their walls, doors, websites, emails, name cards, brochures, etc. it always makes me a bit cynical. Working in a Thai company that recently got their ISO 14001 certificate and visiting many other companies makes me realize that there is a dire need for a local version of the system. ISO systems are western inventions and as such totally in contradiction with Thai culture.

Let’s look at it by some of the pillars of ISO systems;

Sharing knowledge on the work floor, helping each other to learn and do the job right. In Thailand if you have knowledge, that is your asset and part of your value as an employee for the company, you don’t just give that away. So if a colleague doesn’t know what he is doing the others stand around and smile until the job is either done or totally messed up, in general no one will help. When the job Is messed up the one who can do it will tell the boss, I can do it, I’m not stupid, and increase his status in the group and with the boss. The one who lacks the knowledge will also not ask for help in fear of being laughed at and held for stupid. The culture of not asking anything starts at schools, where the few that understand things quickly make fools of the rest.

Another pillar of ISO is the bottom up mechanism of improvement, where workers are required
to constantly provide suggestions and corrections that make the systems work better, safer and more efficient. Nobody in Thailand will ever criticize or attack a system that wast put in place by his boss or an even higher boss, nor will a boss accept it. It ruins your career and makes the boss loose face because of the apparent failure of his system. Also this has it’s roots in the education system where even if you know the teacher is wrong, you will never say so or get in deep trouble if you do so and make the teacher loose face in front of the class. If the teacher says a rabbit is called donkey, it’s called donkey.

And than there is the part that incidents are reported, analyzed and learned from. Not in Thailand, incidents are preferable covered up immediately and have never happened. This can lead to dangerous situations, but when the building collapses in 10 years, none of the involved will be around to face the consequences. If the incident can’t be covered up immediately it’s common that the monkey passes from shoulder to shoulder, nobody acting on it, until it finally disappears. It’s remarkable how many problems, also in Thailand just disappear over time or apparently solve themselves. Another strategy is that the problem is pushed out of the company and lands at a supplier or contractor who is in a weaker position to fight it and has to put up with it. Certainly in consumer related business the problem can also be pushed on the customer, we have enough of those, so to upset a few is no big deal. Anything to prevent that you loose face by acknowledging your mistake and the incident has to be reported up the line to a manager and that he has to tell his boss that the schedule is not made and that it will cost more money to correct the mistake.

Last but not least, ISO works only if you are prepared to constantly innovate and are able to change your way of working rapidly. Here I stop, because changing the way people work is one of the hardest things I’ve encountered in Thailand and a story on it’s own.

My conclusion is that without a localized ISO system with working principles that fit with the working culture all these ISO logo’s are window dressing with some shoveling of paper in the background and no practical use.

Something about transport and disposal of mercury waste.

On the path from waste generator to final disposal there are many hurdles to take. Below follows a global view of rules and regulations we encounter on the way.

International regulations

International movements of hazardous waste are regulated under the Basel Convention and the trade and use of mercury under the Minamata Convention, both are UN bodies.

The Basel Convention provides a framework to secure that hazardous waste is Basel Conventiontransported and disposed in a responsible and traceable way. It regulates the transport and disposal starting at the waste generator to the point where the disposal facility confirms final disposal and with this elimination of the liabilities of the waste generator. The waste generator stays responsible for their waste until it is completely disposed.

The Minamata Convention is aiming to protect human health and the environment from the adverse effects of mercury. As such the Minamata Convention target the use and trade of pure mercury and to limit the generation of mercury waste.

For the transport of mercury waste we have to follow the Basel Convention. Every country that ratified the Basel Convention should have a competent authority that executes and controls the regulations of the convention. These competent authorities are controlling the facilities that accept and process waste under the Basel Convention in their country and control the acceptation of waste. When applying for a Basel waste movement permit the starting point is always the competent authority in the country of origin of the waste. They will check if the waste generator is following the right procedures and provides the right information about the waste, transport and destination. If they are OK, than they will inform their colleagues in the destination country and ask them if they accept the waste to be delivered to the desired disposal facility in their country. This however is not all, the transport will often pass trough other countries and also here the competent authorities has to give permission to pass their territory. Even if the cargo never enters this country and the vessel carrying the containers with the waste only moors at a port this permission is required. Some countries have additional demands like security deposits and a local representative taking care of the shipment to make things more complicated. And to top it all off some countries are under revolution or war causing their authorities to be unavailable or the circumstances not suitable for transport of waste, etc. Depending on the speed of the various competent authorities it will take a while to get a waste movement approved, certainly several months.

Local rules and requirements

Country of origin
Transport Mercury To PortIn many cases the country of origin of the waste has rules and requirements in addition to the Basel Convention. Examples are domestic waste movement permits, specifications of vehicles used for transport, insurances, licenses, storage permits, handling, packaging, etc. The customs in some countries are using special procedures for the export of hazardous waste. All things to cover in time to secure uninterrupted execution of a waste disposal project. As part of the Basel framework the authorities in the destination country are responsible for the audit and control of the disposal facilities in their country. Some authorities however in countries of origin insist on inspecting or auditing a facility before approving a Basel movement application.

Destination country
The destination country can have additional requirements too although this in not common as most destination countries have incorporated the Basel framework in their regulations. Some things should be covered like possible differences in the requirements of securing cargo and maximum weights of trucks etc.

Company regulations

Waste generators
Waste generators, certainly when they are large multinational companies, have their own regulations about hazardous waste and mercury waste. They are generally targeted at minimizing liabilities at any stage of the waste disposal. This could include vendor approval procedures, audits of the disposal plant and even destinations of the remains of the waste after the mercury has been recovered.

Shipping lines

Mercury ShippingShipping lines are a hard one these days several incidents in the past few years have made them much more aware of their risks and liabilities. Many shipping lines now refuse hazardous waste cargo completely. Those shipping lines that still accept it have tightened the rules and their control. Shipping lines now want to make very sure that they have no risk, in some cases every drum and pallet is checked and there need to very detailed reports of loading the containers before they are accepted on board.

Recycling and disposal plants
Disposal plants have their requirements too and that can be about type of material that they can handle or not, level of mercury contamination, delivery schedule as they may have limited storage, transport routes, limits of disposal of secondary wastes after treatment, etc.

Many aspects need to be cleared before you can say that you have finally disposed of your mercury waste!

It’s not easy, but we can do it!

Recycling of catalyst and other metal baring materials for your catalyst recycling expertise!

We are experts in recycling of spent catalyst, sludges, filter cakes, ash, ores, etc containing small or larger amounts of Zn, Cu, Ni, V, Mo, Co, W, Ti, Sn, Pt, Pd, Rh, Au, Ag, etc.

Non Ferrous Metals

  • Aluminum (Al)
  • Copper (Cu)
  • Lead (Sb)
  • Nickel (Ni)
  • Tin (Sn)
  • Titanium (Ti)
  • Zinc (Zn)
Minor Metals

  • Molybdenum (Mo)
  • Cobalt (Co)
  • Tungsten (W)
  • Vanadium (V)
Precious Metals

  • Gold (Au)
  • Silver (Ag)
  • Palladium (Pd)
  • Platinum (Pt)
  • Rhodium (Rh)

We are expert in every step of the way to getting the best value from your waste or by product!

Establishing the value of your materials
We have a wide experience with investigating and sampling all kinds of materials. The first step is always to indicate the value and to establish the feasibility and possible solutions of your project.
Later on we have to establish the exact value of your materials based on samples and analysis in independent laboratories. We are experts in sampling and working with independent essayers and laboratories.

To move materials often classified as “waste” and sometimes as “hazardous waste” legally you need permits. We help you with the paperwork and provide the documents that you need to apply for permits.

Packaging and loading
The right packaging and the right way of loading to optimize transport and safety making sure what you ship arrives at the planned destination in good order. We have the knowledge and experience to organize it all for you.

How to move the materials, shipping lines, trucking, etc. We know them and they know us. Certainly with hazardous materials it takes a good relationship for shipping lines to accept the cargo.

We have in depth knowledge of the processes of recycling for many different materials enabling us to find the best solution and check the results fro you.

End to end
At we take care you your project from end to end covering all aspects of recovering the best value from your waste materials in an environmental responsible way in accordance with local and international laws and regulations.

Mercury Management and Mercury Disposal

Companies in exploration and production of oil and gas and many petrochemical plants have problems to solve involving mercury (Hg).

mercury-monitoringProblems start with mercury sludges from drilling or solids removal, produced sand and water, catalyst or absorbent, contaminated equipment and piping, mercury in reactors, etc.

From that comes mercury waste, spent catalyst or absorbent, sludges, sands and the need to clean or decontaminate equipment, tubing, valves, etc.

Disposal of mercury waste is a specialized field that I have been working in for the past 8 years building knowledge and a network of professional contacts that can take care of all aspects.

Think about mercury management, mercury disposal, decontamination, cleaning, waste logistics, Basel waste movement notification, permits, safe handling, PPE, etc.mercury-waste-shipping

It’s getting more and more difficult to deal with mercury in a proper and legal way, safety issues, company regulations, international bodies like the UN Basel convention, local authorities, logistics, shipping lines, etc. Hazardous waste is a hot issue for many parties that are involved when you start dealing with it.

If you have a problem with mercury or any questions related to mercury, please contact me, I can solve it!


Experts to get the best solutions for your waste project