Status Of Hazardous Waste Management In Brunei Darussalam

 

1. Definition of hazardous wastes
2. Regulations for hazardous waste management
3. Generation of hazardous waste
4. Disposal practices
5. Recommendations

Contents of my presentation is based on available literature regarding status of hazardous waste management in Brunei and on information obtained from the Environment Unit’s own experience in being involved in trying to resolve problems associated with the disposal of hazardous waste. Since the Environment Unit was only established in 1993, we have to admit our experience would not be exhaustive. In this case probably some of the participants today may have additional knowledge regarding hazardous waste disposal practices.

Definition of Hazardous Wastes

Toxic, Hazardous and Difficult Wastes is defined in the Negara Brunei Darussalam Master Plan: Part 11 – Solid Wastes Management as “wastes requiring special measures for storage, transport and disposal because of the potential risks they present to public health and the environment”. Hence, hazardous waste can be in the form of solids, liquids, or sludge that is generated by industrial, commercial, agricultural and domestic activities.

However one should bear in mind that national systems differ both in the methods used for defining wastes and the type of waste included. These differences are partly a result of the variations in the institutional and legal frameworks of different countries. The following are examples of other countries definitions (Malaysia not included as we would have the opportunity to learn more of Malaysia’s experience from Ms. Mariana binti Md. Nor from the Department of Environment, Malaysia):-

Canada, Canadian Council of Ministers of the Environment, consensus documents – “Hazardous wastes are those wastes which are potentially hazardous to human health and/or the environment due to their nature and quantity, and which require special handling techniques.”

Germany, Waste Act 1986, Special Wastes – “…(any waste) generated by industrial, commercial or public sources which by reason of their nature, condition or quantity, constitute a particular hazard to health or the quantity of air or water or are particularly explosive or inflammable, or contain or may lead to the development of pathogenic organisms (transmissible diseases).”

Thailand, Hazardous Substance Act 1992, “the term hazardous waste is applied to any waste containing the following: explosive substances, flammable substances, oxidizing agents and peroxides, toxic substances, substances causing diseases, radioactive substances, mutant causing substances, corrosive substances, irritating substances and other chemicals or otherwise, which may cause injury to persons, animals, plants, properties or environments.

Singapore, Hazardous Waste (Control of Export, Import and Transit) Act 1998 - “hazardous wastes means (i) waste prescribed by any regulations made under this Act, where the waste has any of the characteristics mentioned in Annex III of the Basel Convention; or (ii) waste that belongs to any category contained in Annex I to the Basel Convention, unless it does not possess any of the characteristics contained in Annex III to that Convention”.

UNEP Ad Hoc Working Group of Experts on the Environmentally Sound Management of Hazardous Waste, December 1985 – “Hazardous wastes means waste other than radioactive wastes which by reason of their chemical reactivity or toxic, explosive, corrosive or other characteristics causing danger or likely to cause danger to health or the environment, whether alone or when coming into contact with other wastes, are legally defined as hazardous in the State in which they are generated or in which they are disposed of or through which they are transported.”

(Note: Basel Convention excludes radioactive wastes as they are subject to other international control systems)

There are definitions that exclude domestic solid wastes and aqueous effluents. However, a major source of hazardous wastes is from the pre-treatment of effluents in order to meet water pollution controls, examples being heavy metal sludge from electroplating, sludge from treating sewage etc. Also, the degree of hazard posed by hazardous wastes varies widely hence the need for their identification, classification and categorization. Definitions has also sometimes been complicated by the fact that waste can be recycled or can be used rendering them acquired value and argued as no longer considered to be waste. In this regard there should be no relaxation of controls for recyclable wastes.

Regulations on Hazardous Waste Management

Presently the only Brunei Darussalam law applicable to toxic chemicals is the Poisons Act which regulates pharmaceuticals and pesticides through a regulatory system requiring the import, sale, dispensing or application of the chemicals in the poisons’ list to be licensed. The Act only applies to the substances listed in the schedules which are deemed to be poisons within the meaning of the Act.

Currently there is no law in Brunei Darussalam, and only limited facilities to deal with hazardous waste. There is presently no waste classification system in Brunei Darussalam and apart from the occasional arrangements for special disposal of hazardous wastes, waste generated are either disposed together with household refuse and common landfill sites or discharged in waste water to water courses. At the moment only some of the known sites where dumping have been documented are being monitored for their impact to the environment and potential threat to public health and safety. Examples of these special arrangements will be mentioned later in greater detail under Disposal Practices.

The waste management system and control of toxic chemicals now in place will be inadequate to deal with hazardous waste generated by pollutive industries that utilize chemicals, especially those that are toxic, in their production process. As it is, the Poison Act also cannot be used to regulate handling, transport and disposal of hazardous goods and wastes. This is of particular concern as Negara Brunei Darussalam has plans to diversify the oil and gas industry through the development of downstream activities such as oil refinery and export oriented petrochemical industry. This is in addition to the country’s economic diversification policy to promote the industrial, agriculture and fishery sector.

Hence there is a need for a comprehensive law to cover the entire life cycle of chemicals from the time of their manufacture, import, sale and use, classification, labelling, packaging, handling, storage, transportation and disposal. To this end, a draft Environmental Order has been prepared in which some of you may have been involved in the preparation and review process through the two inter-agency consultations held so far in August 2000 and (month) 2001. Under the draft Environmental Order, the issue of hazardous waste management are covered under Part V Water Pollution Control, Part VI Land Pollution Control and Part VII Hazardous Substances Control. The draft Environmental Order still needs to be finalised. Nonetheless there is already recognition and action initiated to address the law aspect.

Generation of Hazardous Waste

Table 1 provides some illustrative examples of hazardous waste generated by various activities, of which some of them can be found in Brunei Darussalam. Therefore there is a justifiable concern on the adequacy of present waste management system. Unfortunately, in the absence of regulatory control and clear cut responsibility for dealing with hazardous waste there is presently no readily available comprehensive data on the types and quantities of hazardous wastes that are generated in the country. Actual data and estimates are only available for certain activities and types of wastes as follows:

Industrial processes

The oil and gas industry as the major large scale industry in the country is a significant generator of ‘hazardous wastes’ that include oily sludge, waste oils, emulsions, waste drilling mud, produced waters, mercury, oxazolidone, spent catalyst, contaminated sludge and washings. Brunei Shell Petroleum currently produces about 20,000 m3/day of produced water and expected to increase to 32,000 m3/day by 2003. Produce water contain hydrocarbons, production chemicals and heavy metals. In 2001 Brunei Shell Refinery also presently has 10m3 of unused Tetra Ethyl Lead (TEL) and estimated 20m3 TEL contaminated sludge and washings. Last year Brunei Liquefied Natural Gas Plant also had 350m3 of spent sulfinol that contain contaminants such as heavy metals, acids, amines and anions.

Table 1: Some Illustrative Examples of Hazardous Wastes

Expired/obsolete hazardous substances

It had been documented in 1987 that the Forestry Department had nearly 2 tons of sodium arsenate that require disposal. In 1994 the Agriculture Department also had in it possession 3 tons of obsolete Herbicide 2,4,5-T (PCB) that were in their inventory for over ten years during which time its use had already been prohibited. In 1999 there was also an incident requiring the disposal of 40 fire damaged drums of pesticides. The store in which the pesticides were kept by Rico Agencies in Sungai Tilong caught fire. At the moment the Royal Customs and Excise department also has in its possession 68 canisters of liquid chlorine that had been seized and has been in their storage for over 20 years. Due to their age the integrity of the canisters and valves are suspect making potential use of the substance difficult.

Commercial and Household

There had been in the past inquiries by chemicals companies servicing the Ministry of Defence (navy and air-force) seeking advice on disposal of solvents and cleaning chemicals. The Telecoms Department in 1994 had in their inventory 352 acid batteries for disposal. Similarly in 1999 Petrel Jaya Sdn. Bhd. also had in their inventory 20 units of nickel cadmium batteries and 8 units of seal lead acid batteries for disposal. In 2001 Lucent Technologies had in their inventory approximately 7 tons of lead acid and gel type batteries for disposal.

Construction/Demolition Works

1995 the Public Works Department estimated a total amount of 1.2 millition ton of asbestos roofs was planned to be replaced over a four year period.

Disposal Practices

The following illustrates some of the disposal methods that are practiced in Brunei Darussalam:

Direct disposal / no treatment / improper disposal

Due to the inadequacy of present controls or ignorance it would not be wrong to assume that direct disposal of hazardous waste into the environment without proper treatment may occur.

Co-disposal with domestic waste

Depending on the type, quantity and concentration the small quantities of some hazardous wastes have been dealt with by co-disposal with domestic wastes in landfills such as the case for sewage sludge and dry cell batteries for example.

Incineration

Medical wastes are currently incinerated. There are presently two medical waste incineration facilities one in RIPAS Hospital and Tutong Hospital. Some industrial waste have also in the past been mixed with waste oil and used as supplementary fuel for a brick factory.

Burying

Certain hazardous wastes such as asbestos are buried in specifically designated landfills requiring the asbestos material to be packed in plastic. Some obsolete pesticides were also been learned to have been buried with pre-treatment. Small quantities of waste mercury waste have also been encased in concrete and buried with details and location recorded. Unfortunately there have been incidences where past burying practices were done indiscriminately and without proper records.

Injection into abandoned wells

Injection into abandoned wells has been used to dispose BLNG’s spent sulfinol. Injection method is also being considered for waste drilling mud and emulsions.

Recycling

At the moment the only waste recycling facility available is for used lubricants/oils mainly from Brunei Shell Petroleum operations. Currently only a limited amount of non-BSP sources of oil are treated (~4.4 tons in 2001).

Out of Country Disposal

Arrangements for hazardous waste to be exported either to manufacturer of hazardous waste disposal facility. Such movements of wasts are governed by the Basel Convention.

Recommendations

A national control system for hazardous waste management is required having the four important components:

• Legislation and regulation
• Proper implementation and enforcement procedures
• Provision of adequate facilities for hazardous waste recycling, treatment, disposal and measures to encourage their use
• Adequate training for enforcement officers, plant operators and public awareness educational programs.

At the same good information on present quantities of waste and on present practices need to be collected as it is essential to identify priorities especially for development of a national strategy for hazardous waste management that include planning for the provision of facilities.