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March 28, 2019

Recommendations for the Revision of the Basel Convention’s Annex IV and Annex IX (B1110)

Following decision OEWG-11/12 of the open-ended Working Group on the review of the Annexes of the Basel Convention, FEAD, the European Federation of Waste Management and Environmental Services would like to
provide the following comments in view of preparing the recommendations for the revision of Annex IV and Annex IX (B1110) for consideration by the Conference of the Parties during their 14th meeting.


For both disposal and recovery codes, and for a comprehensive understanding of FEAD’s comments on the recommendations for revisions to Annex IV and Annex IX, please find below our guiding principle:

1) As a general statement:
• So far, the current operation codes fit the needs of the waste management operators. Therefore, FEAD recommends choosing a status quo for most of the operation codes.
• FEAD recognises that it is better to keep a general description of each code and to improve the interpretation of the codes with the creation of a guidance document.
2) However, FEAD recognises:
• that certain codes need clarification, and some improvement could bring added value. Nevertheless, a list of techniques should never be considered as exhaustive.
• the need for a “catch-all code” in each respective category: disposal, and recovery codes, as the definition of waste is related to the identification of the operation.


General introduction for Annex IV

Regarding the proposal of a general introduction for Annex IV, FEAD would like to amend it as follows:

ProposalFEAD’s amendmentJustification
Annex IV: Disposal
operations

“There are two categories of
disposal operations, namely
recovery operations and final
disposal operations. Section
A encompasses final
disposal operations and
section B covers recovery
operations.
This Annex covers disposal
operations including interim
operations.
This Annex covers all
operations, regardless of
their legal status and, as
such, regardless of whether
they are considered to be
environmentally sound.
The principal purpose of a
treatment determines the
selection of an operation.”
Annex IV: Disposal
operations

“There are two categories of
disposal waste treatment
operations, namely recovery
operations and final disposal
operations. Section A
encompasses final disposal
operations and section B
covers recovery operations.
This Annex covers disposal
operations including interim
operations.
This Annex covers all
operations, regardless of
their legal status and, as
such, regardless of whether
they are considered to be
environmentally sound.
The principal purpose of a
treatment determines the
selection of an operation.”
Waste treatment operations
consist in either recovery
operations, or disposal ones.
Recovery is not a
subcategory of disposal
operations. « Disposal » was
the general term used for
describing the whole waste
management some decades
ago, but it no longer reflects
the reality, and keeping the
title as proposed would be
inconsistent with the logics of
Disposal & Recovery codes.
Additionally, disposal
operations do not need to be
qualified as final, otherwise
some steps in the chain of
waste disposal will not be
covered.

DISPOSAL CODES

1) Options for captions and introductory texts for Annex IV A

Options
supported
Option 2Final Disposal Operations: A final disposal operation is an operation which is not a
recovery operation even where the operation has as a secondary consequence the reclamation of
substances or energy.”
Options to be
rejected
Option 1 “Operations which do not lead to the possibility of resource recovery, recycling,
reclamation, direct re-use or alternative uses: Section A encompasses all such disposal operations
which occur in practice.”
Option 4 “Final Disposal Operations: A final disposal operation is an operation which is not a
recovery operation. Final disposal operations include operations that have as a secondary
consequence the reclamation of useful materials or energy.”
Option 5 “Final Disposal Operations Which Do Not Lead To The Possibility Of Resource
Recovery, Recycling, Reclamation, Re-use Or Alternative Uses: Annex IV.A encompasses all
operations which lead to or are final disposal operations.”
NeutralOption 3 “Final Disposal Operations: Final disposal operations are those that don’t have as main
purpose to recover resources from wastes, even if the operations recover resources as a secondary
consequence.”

2) In favour of a status quo for the following disposal codes

D2
D3 (strongly against option 1)
D6
D7
D8 (strongly against option 1)
D10
D11
D12
D13
D14

3) In favour of clarification for the following disposal codes

CurrentOptions supportedOptions to be rejected
D1“Deposit into or onto land, (e.g., landfill, etc.)”Option 2
“Deposit into or onto land, (e.g. non engineered landfill, dumpsites) other than by any operations D3 to D5 or D12”
Option 1
“Deposit onto land other than covered by D5, option 1 (e.g. placement of solids, liquids or sludges into pits; permanent aboveground storage)”
D4“Surface impoundment, (e.g., placement of liquid or sludge
discards into pits, ponds or lagoons, etc.)”
Option 1
“Surface impoundment, (e.g., placement of liquid or sludge discards into pits, tailings ponds, tailings dams or lagoons)”
Option 2
“Delete and merge partly with D1, option 1”
D5“Specially engineered landfill, (e.g., placement into lined discrete cells which are capped and isolated from one another and the environment, etc.)”Option 2
“Engineered landfill (i.e. placement isolated from the environment with,
if needed, venting systems,
leachate collection
n.a.
D9“Physico chemical treatment not specified elsewhere in this Annex which results in final compounds or mixtures which are discarded by means of any of the operations in
Section A, (e.g., evaporation, drying, calcination, neutralization, precipitation, etc.)”
Option 1
“Physical/mechanical treatment (e.g. evaporation, drying),
physical/chemical treatment (e.g. solvent extraction) and chemical
treatment (e.g. neutralization, precipitation), immobilization (stabilization, solidification) prior to
submission to any of the operations in Section A.”
n.a.
D15“Storage pending any of the operations in Section A”Option 1
“Temporary storage pending any of the operations in Section A
D15.01: with transfer or repackage D15.02: without transfer or repackage”
n.a.

4) Proposal of new disposal codes

Options supportedD20 and D21 need to be merged:
D20 “Final disposal operations other than covered by D1 option1, D2 option1, D3 option1, D5 option1, D6, D7 and D10 option1”
D21 “Other treatment than covered by D8 option1, D9 option1 and D13 option1”
Options to be rejectedD16 “Release to the atmosphere (e.g. venting of compressed or liquefied gases)”
D17 “Treatment of waste by nanomaterials”
D22 Options 1 and 2 as they are already mentioned in D9 option 1
• Option 1:” Operations addressing stabilization and solidification”
• Option 2: “Immobilization (e.g. stabilization, solidification) prior to submission to any of the
operations in section A”
OtherD19 needs to be merged with D9 option 1 as examples:
“Treatment of sterilization or decontamination of biopathological waste
D19.01: autoclave
D19.02: microwave – radio waves.
D19.03: physical sterilization
D19.04: chemical sterilization
D19.05: other method or technology not specified”

RECOVERY CODES

1) Options for captions and introductory texts for Annex IV B

Options supportedOption 2
“RECOVERY OPERATIONS: A recovery operation is an operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy.”

2) In favour of a status quo for the following recovery codes

R2
R3
R4
R5
R6
R7
R8
R10
R12 (strongly against option 4)

3) In favour of clarification for the following recovery codes

CurrentOptions supportedOptions to be rejected
R1“Use as a fuel (other than in direct incineration) or other means to generate energy”Option 1
“Use as a fuel or other means to generate energy”
n.a.
R9“Used oil re-refining or other reuses of previously used oil”Option 1
“Re-refining of used oil”
Option 2
“Refining of used oils and other reusable fluids”
Option 4
“Recovery of used oil and hydrocarbons
R9.01: filtering or rectification
R9.02: distillation of natural or synthetic hydrocarbon-based waste
R9.03: use without the need of any further operation from this Annex”
R11“Uses of residual materials obtained from any of the operations numbered R1-R10”Option 1
Delete
n.a.
R13“Accumulation of material intended for any operation in Section B”Option 1
“Temporary storage pending any of the operations in section B”
n.a.

4) Proposal of new recovery codes

Options
supported
R14 “Preparing for re-use (e.g. checking, cleaning, repair, refurbishment)”
R16 “Repackaging prior to submission to any of the operations in Section B”
R17Recovery other than covered by R1 option2, R3 option1, R4 option1, R5 option1 and R13”
NeutralR15 “Co-processing”
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