ILA Lead Conference
Prague June 2013
Developing Environmentally Sound Lead Recycling in the Developing World
Brian Wilson
ILMC Program Manager
The International Lead Management Center (ILMC) was founded by the ILA and
ILZRO in 1996 and since then has developed and implemented over 50 Lead risk
reduction programs across the Globe.
The main focus since 2002 has been the Environmentally Sound Management
(ESM) of Used Lead Acid Batteries (ULAB), particularly in developing countries and
more recently in countries in transition such as India and China.
The ILMC promotes the “Good Practices” followed by ILA members in respect of
Environmental Management, Occupational Health, Safety and Community
Engagement and documented in the ILA Guidance Notes.
The ILMC also works closely with the Basel Secretariat and the Regional Centres to
advocate compliance with the Basel Convention and conformance to the Basel
Technical Guidelines with regard to the recovery and recycling of ULAB.
Benchmarking the “Good Practices” associated with the ESM of ULAB is becoming a
cornerstone of many risk reduction programs and the recently developed
Benchmarking Assessment Tool (BAT) is a feature of projects in Central America,
West Africa, India and China.
The ILMC is supported by the ILA members who provide Technical Expertise as
required and “On Site” training for Engineers and Metallurgists in new recycling
processes and Technicians in environmental control systems.
The ILMC works with Governments and their respective environment agencies; UN
Organizations such as the Basel Secretariat, the International Lead Zinc Study
Group, the Common Fund for Commodities, the UN Environment Program and the
UN Conference on Trade and Development. We also work with Industry
Associations such as the Battery Council International, the India Lead Zinc
Development Association and the China Non-ferrous Metals Industry Association.
Since 2001 we have worked closely with the New York based NGO, the Blacksmith
Institute in Africa, Central America and Asia. All the local companies we work with
are not ILA members and so external funding for most of the project work
undertaken is essential.
Working in partnership with the Basel Secretariat, it is important to note their
definition of Environmentally Sound Management, and that is, “The Protection of
Human Health and the Environment”, but interestingly the Basel Convention
advocates an “Integrated Life Cycle Approach” to ESM and “control at every stage of
disposal or recycling”. These two key definitions are consistent with the ILA’s Lead
Risk Assessment which was also based on a Life Cycle Approach.
The ILMC always tries to build into its projects, sustainability, but what does this
mean for Developing Countries and those in Transition?
At the Rio +20 summit in Brazil in June 2012, all the Governments that we work with
were represented and there were significant speeches from the leaders in India and
China, but what does Sustainable Development mean for the companies, people and
governments that we work with?
There are many theories about Sustainable Development, but for ULAB recovery
and recycling there are four main components to consider; the social aspects, the
economics, the available resources and the environment. Only when these
components come together do we achieve Sustainable Development.
What is key to implementing successful Risk Reduction Programs is a clear
understanding of the negative impacts, or obstacles, of these four components in
order to develop strategies to overcome them.
Let us consider the negative social impacts. In nearly all recycling in developing
countries is dominated by the “Informal” sector, which is unlicensed and therefore
unregulated. There are few, if any, environmental controls, leading to high population
and occupational Lead exposure. Working conditions are poor, exacerbated by
manual breaking of the ULAB, and there is little regard for safety. In many cases we
find that the operators are migrant workers, usually without the correct immigration
credentials making them vulnerable to exploitation and unlikely to complain.
With regard to the economics of ULAB recycling, because the “Informal” sector do
not use the appropriate environmental and hygiene control systems and pay low
wages to their workers, they can afford to offer the highest prices for ULAB, indeed
in many instances distorting the price above the level for environmentally friendly
smelters to make a profit.
Furthermore, the “Informals” do not pay taxes and therefore do not contribute to any
social or infrastructure development. If there are any accidents at the plant resulting
in injury or fugitive emissions, the “Informals” are not insured and claims fall on deaf
ears. It goes without saying really that the workers are not well paid.
Finally, you should also be aware that trade imbalances distort ULAB availability and
pricing. For example there is a huge trade imbalance between Central America and
Asia, which means that cargo vessels return from Central America to Asia virtually
empty, and that means the ships require ballast.
What better ballast than ULAB; and it is possible to ship 600 tons of ULAB from
Central America to Asia for US$ 38! Less than the cost of transporting one truck load
of ULAB from El Salvador to Guatemala for recycling. Such trade is not sanctioned
by the Basel Convention, but it continues, and certain smelters in Central America
struggle to secure sufficient supplies of ULAB.
Resource impacts cover a multitude of issues, so let us consider just “six of the best”
for now. Needless to say the lack of pollution controls leads to atmospheric and
environmental contamination. “State of the art” smelting operations will recover up to
99% of the Lead in a ULAB, but the informal sector’s recovery rates are much lower
and sometimes only 50% due to crude furnaces and poor smelting techniques.
Trained furnace operators are a valuable resource themselves, but operators in the
informal sector are not trained and rarely understand the smelting process mainly
due to a lack of training materials.
Few resources are devoted to providing adequate personal protective equipment
(PPE) and even less into providing amenities such as wash rooms and clean
canteens. All these shortcomings are possible because all too often the local
environment agencies are under-resourced and fail to apply the full force of the law
against the “Informals”.
If government agencies do manage to close down an informal operation, the site is
invariably contaminated and unsuitable for alternative use until it has been
remediated, and normally site remediation is a very expensive operation. In nearly all
developing countries the battery electrolyte is drained into the environment without
any treatment, and this practice is perpetuated because the prices paid for ULAB in
the “Informal” sector are for “dry” ULAB. Reconditioning of ULAB is widespread, that
is the cannibalization of ULAB to rebuild a “spent” battery with one or more working
cells. Whilst reconditioning does prolong the life of a battery, the process involves
the discarding of battery electrolyte and exposure risks to the operators. Furnace
residues, usually rich in Lead compounds are discarded and often into fast flowing
rivers.
There are also instances where certain operations that have installed baghouses
that they are switched off at night to “save” electricity. Finally, on rare occasions
where ULAB are delivered complete with electrolyte, the smelter does not have an
effluent treatment plant and any liquid residues are dumped into the environment of
the nearest river.
Given an understanding of the obstacles to ESM and Sustainable development
potential projects are selected with care, because the ILMC cannot implement a risk
reduction program on its own, partners are essential and they include; the Lead
Industry and the respective industry associations, where appropriate InterGovernmental bodies and an NGO or a local community group.
It is vital to confirm the commitment of the national and local government offices to
the introduction and implementation of ESM, because without it, the “Informals” will
continue to operate and the project will fail. Finally, it is essential to secure external
funding, and this is where partnerships are so important, because donor countries
and organization will not support the Lead Industry with direct funding.
Having assembled all the pieces for the “Jigsaw”, how do we put it together?
Firstly, we need to Benchmark the existing ULAB recovery and recycling operations
covering ULAB collection, temporary storage, transportation and smelting. Then we
can decide whether the best options are nationally based or are better suited to a
regional approach. Whatever approach is agreed, the Government regulatory
agencies understanding of the parameters for ESM and Sustainability need to be
strengthened so that they can apply the Industry norms for “good practice” when
they inspect a plant or consider a license application. To this end a series of
workshops covering the use and application of the Benchmarking Assessment Tool,
the Basel Technical Guidelines and the ILA Guidance Notes are held.
The Lead Risk Reduction improvement programs can then be implemented, making
sure that, in the case of a regional solution, there is full compliance with the Basel
Convention, that is, that the ULAB are correctly classified, that the export or import of
the ULAB is expedited without undue delay and properly recorded.
Finally, every effort is made to convert the environmentally unfriendly “informal”
recyclers into compliance and bring them into the licensed formal sector.
That is the theory, but over the years, “have we been successful?”
Let me take you back to 2002 in the Dominican Republic and these are photographs
of the Lead Smelter that I inspected as part of a project with the Basel Convention. In
2012 the new Lead Smelter was commissioned, complete with dedicated vehicles for
ULAB collection, a 14 tons per hour capacity mechanical battery breaker, effluent
treatment and enclosed rotary furnace. The door is open here to view the tapping
operation and the fume capture.
This is Guatemala in 2004 and the ULAB are stored on open ground. Today they are
delivered shrink wrapped and stored under cover. Furthermore the site has been
transformed and the company has won two national and two regional awards for its
environmental performance.
This is Costa Rica in 2005 showing the battery breaker and a rotary furnace
operation. Last year the new recycling plant was commissioned with a new heavy
duty mechanical battery breaker, hygiene and furnace ventilation to separate
baghouses, an elevated effluent treatment plant to compensate for the rainy season
and it also produces Gypsum as a bi-product, and installed is an enclosed front
tapping rotary furnace with an oxy-fuel waste oil burner.
Here we see where battery grids were melted to produce Lead ingots in a suburb of
the Senegalese capital, Dakar. The melting pot is missing because it was being used
in the kitchen to prepare the evening meal for the family. This is the pond in the
village where the separators and other unwanted battery components were dumped
by the villagers involved in the battery recycling. The Blacksmith Institute worked
with the Government to remediate the village and remove the toxic contamination,
but this would have been a pointless exercise unless an environmentally sound
recycling option for the ULAB was found.
Accordingly, the ILMC, with support from the International Lead Zinc Study Group,
worked in partnership with the Basel Convention Regional Centre, Industry partners,
Gravita Senegal, and the Environment Ministry to move towards the provision of
Environmentally Sound ULAB recovery and recycling culminating in the
commissioning of a new smelter in 2010. About 48 local people are employed at the
site and are provided with clean work clothes, PPE and washing facilities. The
operation has emission controls, and despite the furnace technology being
somewhat dated, the manual charging, tapping and casting processes are properly
controlled and emission free. The operation complies with all prevailing
environmental legislation and is fully licensed.
The lead risk reduction project in Senegal could not have been resolved without the
close cooperation between the ILMC and the Blacksmith Institute. Whilst the
respective roles were clearly defined, each organization was dependant on the other
to achieve their own objectives.
It was a complex problem of Lead exposure and the resolution required the resolve
of the Government to tackle the “Informal” recycling activities, the Blacksmith
Institute to secure sufficient funds to undertake the soil and household remediation
program and the ILMC to find an Industry partner willing to invest in “clean” ULAB
recycling.
This “Integrated Approach” was now to be a model for further cooperation between
the Blacksmith Institute and the ILMC. Now we share a lot more information and
together we try to identify lead exposure issues and opportunities to promote
environmentally sound ULAB recycling. Then lead exposure and compliance levels
are determined, and if there is a viable project, partners and their commitments are
secured. Project plans, timelines and roles are discussed and confirmed along with
funding. Such Projects would then be implemented in four phases as follows: an
information phase to outline to regulators, local communities and smelter managers
pathways to manage ULAB recycling in an environmentally sound manner; followed
by a phase to direct all interested parties towards the best options to resolve
exposure issues; the third phase would be to support the implementation of the
project in every way possible and finally to follow up and monitor progress as the
project develops.
For some years the ILA and the ILMC have been supporting the workshops and
seminars organized by the India Lead Zinc Development Association (ILZDA). But
now at the suggestion of the India Lead Zinc Development Association, the ILMC
and the Blacksmith Institute will be targeting six provinces in India that have been
identified with significant “Lead Hot Spots” with the objectives of reducing or
eliminating the current and past adverse impacts of the “informal” sector and
establishing a partnership between the provincial Pollution Control Boards and
members companies of the India Lead Zinc Development Association to achieve the
ESM of ULAB throughout each stage of the Life Cycle.
To date we have held preliminary discussions in Kolkata with the West Bengal
Pollution Control Board.
In Bangalore we have held a Benchmarking Assessment Training Workshop for
twenty four technicians and environmental engineers from the Karnataka Pollution
Control Board to familiarise them with the optimal ULAB recovery and recycling
practices.
Similarly, and as the first phase of the strategy, we held a second BAT workshop in
Chennai at the invitation of the Tamil Nadu Pollution Control Board for twenty four of
their staff.
Well, I am delighted to inform you that both Directors from the Karnataka and Tamil
Nada Pollution Control Boards have confirmed their commitment to the Blacksmith
Institute to move forward and identify sites in need of remediation, and to the ILZDA
and the ILMC to establish a project to deal with the “Informal” sector and strengthen
the environmental performance of the licensed formal sector.
In October we plan to hold at least two more workshops and follow up with firm
project proposals for Karnataka and Tamil Nadu.
The increase in Lead Bullion and Refined Lead production in China over the past ten
years has been phenomenal and today China produces approximately half of the
Global Lead production.
But as we know, China’s industrialization has come at a price, and the Lead Industry
has not been immune from problems associated with occupational and population
lead exposures, fugitive emissions and water pollution.
Just before the Beijing Olympics in 2008, the Chinese Government decided to make
a concerted effort to eliminate the most polluting ULAB recycling plants and in
Beijing alone closed about 300 small scale operations. This closure program
continued, but increasingly the focus was changing from environmental compliance
to location, that is, proximity to local populations and annual production capacity.
Such a change in direction away from performance based evaluation of
environmental and health performance was a concern to the members of the China
Non-ferrous Metals Industry Association, the CNIA, some of whom have state of the
art facilities.
As part of the Association’s efforts to persuade the Government to return to an
entirely performance based approach to licensing recycling plants, the CNIA is
trialling the BAT Process with selected Companies in order to Benchmark the
Chinese smelters against International Operational Practices to demonstrate to the
Government that the Industry can and does follow working practices that are
consistent with environmentally sound management, safe working and good
occupational health.
The first of such trials took the form of a Training Workshop organized by the CNIA
at a recycling plant in Xuzhou and under the direction of the Basel Convention
Regional Centre for Asia and the Pacific and the ILMC, with participation from the
Blacksmith Institute and the full support of the local environment agency.
The CNIA is now considering the outcomes of the workshop with a view to extending
the scope of the Benchmarking exercise to all the member companies to build up a
data base to present to the Government for their consideration.
Thank you
BW/ILMC/June 2013