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RE-USE, RECYCLING AND/OR DISPOSAL OF SOLID AND LIQUID WASTE, PACKAGING MATERIALS AND LEFT-OVERS

EFMA PRODUCT STEWARDSHIP FOR FERTILIZERS

Version 1.5: 01-08-2009

3.1.9 RE-USE, RECYCLING AND/OR DISPOSAL OF SOLID AND LIQUID WASTE, PACKAGING MATERIALS AND LEFT-OVERS.

INTRODUCTION

One of the objectives of EFMA's Product Stewardship program is to minimize safety issues and environmental impacts from wastes and non-conforming materials. This involves the re-use, recycling and proper disposal of solid and liquid waste and packaging material, and the correct treatment of off-spec and refused products.
The first step is to establish the fate of all impurities and of waste products.

LEGAL REQUIREMENTS

There are no legal requirements to establish the fate of waste products, though the consideration of the environmental fate is a good practice for Responsible Care companies.

EFMA REQUIREMENTS

The following aspects have to be taken into account:

1) Risk for the environment (Responsible Care: no risks for man and the environment; part of the risk management process)
2) Risk to the customers (risk to the users of the product involved in any possible exposure).
3) Risk to the business (continue or not with a product; see also EU Policy on Chemicals chapter 3.1.5.3.)

For defining the risk to the environment and user.

How many product is manufactured?
What is the use/misuse of the product and how is it applied?
What are the exposure and disposal data?
What are the disposal patterns for product/ impurities/wastes at each stage of the lifecycle?
What are the user competence, facilities and know-how?
What are the toxicity and eco-toxicity hazards?
Is the product handled is a safe way?
Compliance with regulatory requirements on use and disposal?
Knowledge on previous incidents and accidents?
Information on and training in safe disposal?
Are impurities/by-products present?

How to achieve:

Auditable system for environmental fate in place?
Market use, exposure and disposal data; monitoring changes in use/disposal
Written procedures on roles and responsibilities.
Periodically audit against the defined systems and procedures.
Corrective and protective actions.
Partnership with distributors, users and waste disposers is useful.

For new products see also chapter 3.1.2.

EFMA IMPLEMENTATION

3.1.9.1. ESTABLISH ENVIRONMENTAL FATE OF ALL COMPONENTS/IMPURITIES AND OF WASTE PRODUCT.

Establish environmental fate of individual components and significant impurities and the fate of contaminated packaging.

Typical waste materials from a fertilizer production site are:

1) Catalysts

Catalysts containing chromium, nickel, iron, copper, and mineral/ceramic support materials (ammonia production)
Platinum/rhodium catalysts (nitric acid production).
Vanadium catalysts (sulphuric acid production).

For environmental and cost reasons these catalysts are returned to the catalyst producers for rework or handled as dangerous waste.

2) Resins

Resins from boiler feed water treatment (ammonia production). These resins are returned to the resin producer.
Water treatment resins (nitric acid production). There resins are regenerated/recycled.

3) Products

Fertilizers are derived from naturally occurring materials, such as nitrogen (from air), and rock phosphates (from mining operations) and are intended for growing crops. In modern agriculture fertilizers are used in an efficient way with no or little left-over wastes. Any left-over material should be returned to the supplier and/or disposed of in an environmentally friendly way.
Contaminated material must be handled safely (see chapter 3.1.4.3. and 3.1.7.2.)

4) Packaging/pallets
Internally at manufacturing plants and distribution warehouses: by recycling to waste handlers. externally by customers: advising on national schemes for recycling.

5) Lubricating Oil

Periodic replacement is needed of the lubrication oil in rotating machines such as compressors, turbines and pumps.
Used oils should be returned to recycling operators.

6) Gypsum

Gypsum from phosphoric acid production should be disposed of as agreed with local authorities. In new plants phosphogypsum should be disposed of to land. The system should be designed to prevent any contaminated water from reaching the surrounding groundwater system (EFMA BAT booklet nr. 4)

7) Waste water

Waste water is recycled or treated in a physical-chemical waste water treatment unit or biological waste water treatment unit.

8) Heavy metals in fertilizers

Heavy metal impurities are an inevitable issue related to phosphate fertilizers. They originate from the raw material rock phosphate. Only by selection of the phosphate rock the content in the end product can be controlled.
(see also chapter 3.1.1.1.)

9) Additives/coatings
Waste materials of additives and coatings should be treated by recycling operators.

3.1.9.2. WASTE MINIMISATION AND DISPOSAL

Reduction of waste as a starting point; waste management strategy

LEGAL REQUIREMENTS

EU Waste Legislation is regulated in the so called Waste Frame Work of the European Commission.
The original basic directive is the Waste Directive 75/442/EEC establishing the basic principles such as prevention, minimizing, recycling and re-use. It introduces permit requirements for waste processing and disposal and makes it necessary to keep a record which covers waste type, quantity, origin, the destination, frequency of collection, mode of transport and treatment methods.
This Directive was amended by Council Directive 91/689/EEC of 12 December 1991 on Hazardous Waste which categorizes hazardous wastes and which includes more severe measures regarding record keeping and waste management plans. It also requests to drawn a more specific list of hazardous wastes. This list was issued in Council Directive 94/904/EC of 22 December 1994.
Council Directive 94/904 has been amended by Commission Decision 2000/532/EC of 3 May 2000 and subsequently by Commission Decision 2001/118/EC both latter ones in force, the first one repealed as from January 1, 2002.

Relevant wastes as listed in Directive 2001/118 ((*) Hazardous)
- waste gravel and crushed rocks
- Waste sand and clays
- Dusty wastes
- Wastes from potash and rock salt processing
- Agrochemical waste containing Dangerous Substances *
- Agricultural waste plastic (except packaging)
- Hydrofluoric Acid*
- Phosphoric Acid*
- Sulphuric Acid*
- Nitric Acid*
- Heavy metal containing wastes*
- Sludge's from on-site effluent treatment containing dangerous substances*
- Calcium based reaction wastes form phosphorous chemical processes containing or contaminated with dangerous substances*
- Aqueous washing liquids , organic solvents, and mother liquors*
- Etc.,

It should be noted that packaging is not regarded as hazardous waste.
In addition to the named "General Directives" there are four groups of Directives addressing special wastes, processing and disposal facilities and shipment of waste..
Relevant to the Fertilizer industry are:

Special wastes

1. Sludge's 86/278/EEC
2. Packaging 94/62/EC see also chapter 3.1.4.6.

Processing and disposal facilities

1. IPPC 96/61 EC
2. Landfill of Waste 1999/31/EC

Shipment of waste

1. Shipment of waste Regulation (EC)1013/2006

Wastes from the extractive industries

Extractive industries meaning all establishments and undertakings engaged in surface or underground extraction of mineral resources for commercial purposes including drilling boreholes, or treatment of the extracted material.

1) Directive 2004/35/EC, of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage . OJ L143 30-04-2004 p56

2) Directive 2006/21EC of the European Parliament and the Council of 15 March 2006 on the management of waste from extractive industries and amending 2004/35/EC. OJ L102 11-04-2006 pages 15-34.

Directives on Waste and Hazardous Waste

Council Directive 75/442/EEC of 15 July 1995 on waste OJ L194, 25-07-175 p39

Council Directive 91/156/EEC of 18 March 1991 amending Directive 75/442/EEC on waste. OJ L78, 36/03/1991. P. 32

Council Directive 91/689/EEC of 12 December 1991 on hazardous waste. OJ L377. 31.12.1991 p.20

Commission Decision of 3 May 2000/532/EC replacing Decision 94/3/EC establishing a list of wastes pursuant to Article 1(a) of Council Directive 75/442/EEC on waste and Council Decision 4/904/EC establishing a list of hazardous waste pursuant to Article 1(4) of Council Directive 91/689/EEC on hazardous waste. OJ L226, 6.9.200 p.3

Commission Decision (2001/118/EC) of 16 January, 2001 amending Decision 2000/532/EC as regard to the list of wastes. OJ L47 16.2.2001

Directive 2004/35/EC, of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage . OJ L143 30-04-2004 p56

Directive 2006/21EC of the European Parliament and the Council of 15 March 2006 on the management of waste from extractive industries and amending 2004/35/EC. OJ L102 11-04-2006 pages 15-34.

Regulation (EC) No 1013/2006 of the European Parliament and the Council of 14 June 2006 on shipments of waste. OJ L190 12-07-2006 pages 1-98

Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain Directives OJ L312 22-11-2008 page 3

For Packaging an packaging waste see also chapter 3.1.4.6.

3.1.9.3. CUSTOMER WASTE

Advice to customers and product users on the disposal of packaging, waste product and end-of-life product. It excludes the specific obligations on producers for packaging waste.

LEGAL REQUIREMENTS

For products which are hazardous, advice for customers on product disposal must be provided through section 13 of the Safety Data Sheet: Disposal Considerations.

EFMA REQUIREMENTS

Suppliers should look for opportunities to work actively with their customers and to help the latter dispose of any product-related waste safely. (It is important not to take on liability - advice should be offered in a way that customers retain responsibility for their risk prevention and management measures.)
For products not requiring a Safety Data Sheet, suppliers should still provide appropriate disposal advice by the most effective means, taking into account the capabilities of the customer.

How to achieve

Identify significant wastes (unused products ; packaging waste)
Assemble information on the health, safety and environmental fate (re-use, reprocessing, recycling, incineration, landfill or release to the environment) and hazards of such waste. Check the relevance of the company's own practices and procedures to waste disposal by customers.
Access commercial and environmental benefits : give advice to customers on :
o Regulations
o In-house procedures
o Skilled help and assistance from supplier
o Choice of contractors for disposal
o Initiate waste management studies, resolve problems
o Set up processes
Identify recycling possibilities
Implement

3.1.9.4. ESTABLISH GUIDANCE FOR NON-CONFORMING MATERIALS

EFMA has established guidance for safe handling and utilization of non-conforming fertilizers and related materials for fertilizer producers and a similar guidance document for distributors. These guidance documents contain valuable information how to safely deal with left-overs (see chapters' 3.1.4.3. and 3.1.7.2.).

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