CHAPTER I
INTRODUCTION
1.1
Pollution Prevention – A New Agenda to Toxic and Hazardous Waste
Management
Traditionally, environmental protection efforts have emphasized control of
pollution after it has been generated.
Although this approach may, in many circumstances, be effective in
protecting human health and the environment this method of waste management has
certain disadvantages. Specifically this type of pollution control does not always
solve the problem of pollution, rather, it often transfers pollution from one medium
to another, resulting in no environmental benefit (Dupont, R.R, et. al, 2000).
In addition, management of waste after it is generated requires investment in
pollution control equipment and expenditures of material and energy that would not
be required if the waste is not generated. Because of the growing appreciation of the
benefits of waste avoidance, the overall approach to waste management in the
Malaysia has begun to shift from pollution control driven activities to pollution
prevention activities as suggested in Table 1.1.
In general, pollution prevention suggested the hierarchy for management of
waste as shown in Figure 1.1:
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
Source reduction

Recycling

Treatment

Disposal
Table 1.1:
Evolution of Waste Management Approaches in Malaysia
Year
Approaches
Prior – 1970
No Control
1970 – 1974
Some / little control
1974 – 1980
Greater control, Environmental Quality Act came into force
1980 – 1985
More sophisticated control, Department of Environment, Malaysia
established
1985 – 1990
Beginnings of hazardous waste management
1991 – 1996
Waste reduction management, Malaysian Agenda for Waste
Reduction (MAWAR) launched
1997 – 2000
Widespread acceptance of Pollution Prevention
> 2000
1. Waste
Reduction
Can quantify
of waste
produced be
minimized?
Sustainable Development, Cleaner Technology Design for
Environment
2.Reuse/
Recycling
Can waste be
reused or
recycled?
3. Treatment
Does
hazardous
nature of waste
need to be
reduced?
4. Safe
Landfill
Disposal
Source: Department of Environment, 2002.
Figure 1.1:
Waste Management Hierarchy
There are significant opportunities for industry to reduce or prevent pollution
at source through cost-effective changes in production, operation and raw materials
use, which will result to have reduce of wastes. The opportunities for sources
reduction are often not realized because existing regulations, and the industrial
resources they require for compliance, focus upon treatment and disposal rather then
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source reduction. Source reduction is fundamentally different and more desirable
than waste management and pollution control. (Sinha, R.K., 1994 and Bishop. P. L.,
2000).
Whilst, pollution that cannot be prevented should be recycled in an
environmentally safe manner. This secondary approaches, recycling, reuse and
recovery attempt to recover a usable material from a waste stream. The methods
involve can take place within the process, or at the end of the process and can be
implemented either on or off-site (Nemerow, N. L., 1995).
In the absence of feasible prevention or recycling opportunities, pollution
should be treated; disposal or other release into the environment should be used as a
last resort.
Figure 1.2, depicts the hierarchy of preferred approaches to integrated waste
management, and ultimately pollution prevention.
FOCUS
STRATEGY
Eliminate
Pollution
Recycle
Prevention
Reuse
Waste Management
Reduce
Treat &
Dispose
All Media
Air, Water, Soil
Raw Material Use
Waste Management
Control &
Disposal
Energy
Source: Modified from Dupont R. R, Theodore, L. and Ganesan, K., 2000).
Figure 1.2:
Pollution Prevention Hierarchy
Impacts of
Products
Personnel Management
Work Procedures
4
Pollution prevention hierarchy can be depicted as an inverted triangle, where
the area of the band denoting the management option is indicate of the amount
pollution involved. The objective of pollution prevention is to make the pointed base
as small as possible.
Consequently, the somewhat broader term ‘pollution prevention’ has an
evolving definitions that includes:

Managing chemicals to reduce risk

Identifying and estimating all release

Waste minimization
An overview of pollution prevention techniques is illustrated in Figure 1.3.
This chart provides clear establishment of priorities in toxic and hazardous waste
management ranging from changing products, recycling (recovery, reuse and
reclamation), to ultimate disposal of the toxic and hazardous waste that cannot be
avoided (La Grega, M,D., et.al., 2001).
Thus pollution prevention requires a holistic approach to waste management
(Freeman, H.M.,1995 and Sikdar, S.K. and Urmilla Diwekar, 1999). Rather than
waiting until after a waste is produced and then attempting to make it innocuous, the
pollution prevention approach considers the entire life of a product, from extraction
of raw materials through manufacturing to product use and to product and waste
disposal and possible recycling or recovery, in order to find ways to minimize all
environment impacts.
1.2
Statement of Need
The rapid development of manufacturing, agricultural and commercial
industrial in Malaysia have contributed tremendous economic contribution to the
country. As such, economy is seen as generating pressures for outward growth as the
investment has contributed greatly to the shining performance of the manufacturing
sectors (Eight Malaysia Plan, 2001-2005) while the environment presents
unavoidable constraints.
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Pollution Prevention Techniques
Pollution
Techniques
Other Prevention
of Exploration
First
High First
Last
RelativeOther
Environmental
Desirability
of exploration
High
Relative environmental desirability
Source Reduction
Last Low
Low
Recycling (on-and off-site)
Source reduction
Recycling (on-and off-site)
Source Reduction
Source Control
Input Material Changes
Input Material Changes
 Material purification
  Material
Material purification
substitution
 Material substitution
Technology Changes
Good operating practices
Technology Changes
Good Operating Practices
 Process changes
 Procedural measures
 Process
changes  Loss prevention
 Procedural measures
 Equipment,
piping
 layout
Equipment,
 Loss
prevention
or
changes piping or
 Management
practices
layout
changes

Management
practices
 Addition
automation
 Waste stream
 Addition
automation segregation
 Waste stream
 Changes
in
 Changes
in operating
segregation
operating
conditions
 Material handling
conditions
 Material handling
improvements
improvements
 Production scheduling
 Production scheduling
Product changes
 Product
 substitution
Product substitution
Product conservation
 Product
 conservation
Charges in prod.
Composition
 Charges
in prod.
composition
Source Control
Reuse
Reuse
 Return to original

 process
Return to original
process
 Raw
material

 substitute
Raw material
for substitute
for another
process
another
process
Recovery
Recovery
Processed for
 Processed
for
resource
recovery
resource
Processed
as recovery
a by Processed as a byproduct
product
Source: La Grega, M.D., et. al. 2001.
Figure 1.3:
Pollutant Prevention Techniques
This resulted a number of environmental related problems surfaced parallel to
development efforts. At the same time, unavoidably these sectors and their
production activities have led to generation and accumulation of waste materials,
which could be categorized under toxic and hazardous wastes. These kinds of waste
materials are better known as scheduled wastes under the Environment Quality Act,
1974 (Mariana Md. Nor, 1998, and Lee, Heng Keng, 2003).
6
In 2001, a total of 420,198 tonnes of scheduled wastes were produced by
3,741 waste generators in Malaysia (Department of Environment, Malaysia,2001).
As Malaysian gains momentum in her efforts to achieve industrial status by
the year 2020, efforts to minimize waste generation, recycle waste and adopt
pollution prevention measures must be intensified, The scheduled waste generated
from those industries described require environmentally sound management
especially in the areas of safe handling and recovery to ensure the safety and security
of the environment.
According to the Malaysia Environmental Quality Report 2001, current
estimates indicate that metal, chemical and electric and electronic industries made up
the main categories of scheduled waste generator in the country. The breakdown
according to waste categories and industry types are given in Figure 1.4 and Figure
1.5 respectively.
WASTE CATEGORY
35.86
Dross/ Slag/ Clinker
Mineral Sludge
21.33
12.78
Oil & Hydrocarbon
10.4
Heavy Metal Sludge
5.37
Others
3.06
Acid/ Alkali
2.38
Clinical
2.21
Paint/ Ink/ Dye/ Solvent
Rubber & Latex
1.57
Ink/ Paint/ Dye Solvent
1.26
Containers
1.11
Total Quality of Waste Generated :
420,198 Tonnes / Year
0.52
On Halogen Solvent
Phenol/ Adhesive/ Resin
0.46
Catalyst
0.43
Paper & Plastic
0.39
0
5
10
15
20
25
30
35
PERCENTAGE (%)
Source: Malaysia Environmental Quality Report, Department of Environment, 2001.
Figure 1.4: Quantity of Scheduled Wastes Generated by Waste Category
40
7
INDUSTRY
35.12
Metal
16.48
Chemical
14.15
Electrical & Electronic
6.43
Others
5.49
Machinery
Rubber & Plastic
3.73
Power Generator
3.71
Prescribed Premises
3.53
2.99
Petroleum
2.23
Textile
Clinical / Hospital
1.87
Printing & Packaging
1.56
Industrial Gas
1.51
Paint Manufacturing
1.19
0
Total Quality of Waste Generated :
420,198 Tonnes / Year
5
10
15
20
25
30
35
PERCENTAGE (%)
Source: Malaysia Environmental Quality Report, Department of Environment, 2001.
Figure 1.5: Quantity of Scheduled Wastes Generated by Industries
While in the earlier years of waste management, the Department of
Environment (DOE), Malaysia has adopted an open attitude and permitted such
waste to be freely exported. Some of these wastes are sent overseas to the United
States of America, Netherlands and Japan for recovery and disposals understandably
to promote environmental protection in the absence of local facilities for recovery
and disposal. In 2001, a total of 2,675 tonnes of scheduled wastes were exported. The
exported waste were derived from twenty one (21) waste generators and comprised
of sand blasting material (19 tonnes, 0.7%), glass (45 tonnes, 1.7%), spent industrial
catalyst (816 tonnes, 30.5%) and metal hydroxide sludge (1795 tonnes, 67.1%)
(Department of Environment, Malaysia, 2001). The wastes were exported for
recovery in foreign countries as shown in Table 1.2 (Department of Environment,
Malaysia, 2001).
40
8
Table 1.2: Quantity of Scheduled Wastes Exported (Tonnes) 1997-2001
Country
1997
1998
1999
2000
2001
Australia
-
638
280
69
-
Germany
-
-
80
470
159
Holland
-
1,500
1,266
1,234
487
Italy
-
-
-
-
107
450
740
1,103
1,530
68
France
-
150
80
108
-
Philippines
-
-
1,073
-
532
Singapore
-
-
27
500
-
South Africa
-
-
45
-
-
South Korea
-
-
23
-
-
Sweden
-
60
102
203
27
Switzerland
-
-
-
10
-
USA
674
610
1,107
753
1,295
Total
1,124
3,698
5,186
4,878
2,675
Japan
Source: Malaysia, Environmental Quality Report, Department of Environment, 2001.
The Department of Environment, through its vision of encouraging local
capacity for conservation has started to tighten it export procedures to justify such
move. In this regard a lot of project proponents have seen to obtained the technology
for recovery to be set up in Malaysia. According to the Malaysia Environmental
Quality Report, 2001, to date there are twenty-seven (27) licensed recovery facilities
have bean operated in Malaysia (Department of Environment, Malaysia, 2001)
The International development especially in the area of unfair linkage of trade
to environment, the requirements of Basel Convention, coupled with the pending
adoption of ISO 14000 mean that it would be prudent and necessary for Malaysia to
adopt early measures to ensure that:

It products such as fuel oil, palm oil, electrical and electronic components
and others which depend much on international market have credible
component on waste management;
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
The premises involved in the production of the process products, by making
effort towards recovering whatever wastes generated would be moving
towards complying with ISO 14000 requirements, Such contribution
towards certification, would bypass any attempt to link environmental issue
to trade;

The requirement to minimize waste generation and treatment at source
through recovery and minimizing transboundary movements of waste are
met;

Malaysia is party to the Basel Convention, and by treating wastes at sources
not-only complies with the obligations as a party, it would also reflect well
on image of Malaysia in dealing with toxic and hazardous waste
management; and

The setting up of the local recovery facilities would also forestall and
present the difficulties faced by local waste generators with the growing
reluctance of importing countries to receive foreign wastes.
All the above justifies the needs for Malaysia to establish its own capacity in
waste recovery and reuse in the most expeditious manner:

Contributes towards compliance of Basel Convention;

Promotes conservation of resources by recovery and reuse of wastes;

Reduce pressure on and lengthen the economic life of the ultimate waste
disposal through volume reduction of toxic and hazardous wastes that have
to undergo final disposal;

Prevent illegal disposal of wastes from occurring;

Minimize environment contamination;

Minimize accidental spill through hauling of wastes over long distance
across land and sea to other countries; and

Recovered and recycled wastes become a raw material for the same and
alternative users. Recovery and recycling help to conserve resources, which
are finite and non-renewable.
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Indeed, the recovery of scheduled wastes activity is highly encouraged since
they could contribute to the reduction of quantity of scheduled waste to be disposed
of and the products from these activities are found to have value and are reusable as
consumer items. Such recovery activity is good for national economic and industrial
development. It also assists in solving the problems in environmental and scheduled
wastes management. Thus, the Government through the Department of Environment,
Malaysia has implemented a decree that recovery activities need to be controlled and
monitored in order to ensure that the handling and management of scheduled wastes
are in accordance to the Government’s requirements. In this connection also, the
Department of Environment has deemed the scheduled wastes’ recovery activities as
prescribed activities that need to be licensed by the Department of Environment,
Malaysia (Rosli Zul, 1999). Under the Environmental Quality (Prescribed Premises)
(Scheduled Wastes Treatment and Disposal Facilities), Order 1989, the off-site
recovery facilities is defined as premise occupied or used for the recovery of material
or product from scheduled wastes which are not produced on these premises. Thus
procedure in assessment of licensing and inspection of scheduled wastes
management facilities need to be reassessed in managing the increasing numbers of
off-site recovery facilities in the country.
1.3
Aim and Objectives
The aim of the study is to demonstrate and assess the overall policies and
procedure of toxic and hazardous management in Malaysia particularly licensing and
inspection of scheduled waste facilities.
The objectives of this study are as follows:
i)
To evaluate the off-site recovery facilities in Johor, analyze and reassess the
recovery procedure in relation to the Department of Environment’s,
requirements, inspection and reporting network; and
ii)
To document the compliance of licensing conditions of the off-site recovery
facilities in helping responsible authorities or agencies in monitoring and
formulating the best management practice of toxic and hazardous wastes
management.
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1.4
Scope of Study
The study will focus on legislation, institutional and management system
frameworks and procedural aspects in toxic and hazardous waste management. The
study will involve the reassessment of the Department of Environment’s procedures
to the off-site recovery facilities in Johor. The study will focus on the assessment of
licensing and inspection of the off-site recovery facilities by using the licensing
approval conditions due to limitation of the methods and study period. Thus, this
study will provide baseline information for decision makers and enforcement
agencies particularly the Department of Environment Malaysia who are involved in
the toxic and hazardous waste management in the country.