Summary of Recommendations presented in Preliminary Report continued

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Recommendation 1: To introduce Systems to Improve Waste Data

Construction & Demolition Wastes

• Ensure that procedures at the Maghtab Landfill record deliveries of all C&D wastes. The weighbridge records need to be able to be interrogated by waste type in order that accurate data on C&D wastes can be obtained.

• Undertake sample surveys at private and unofficial (inert) waste disposal sites over a 6 month period, observing types and general weights of loads being deposited. This will enable a better understanding of the use of such sites and the tonnage of waste deposited.

• Undertake sample surveys of key C&D waste generators such as hardstone and softstone quarry operators to gain an indication of the levels of waste generated. Compare estimates of wastes produced with quantities of material quarried to determine if any relationship exists and which could be used as a basis for forecasting waste arisings.

Municipal Solid Wastes

• The quality of available data on MSW is better than for any other waste stream. Weighbridges should be installed at all existing and at new waste disposal facilities, and procedures put in place to record the tonnage, source, carrier and type of waste delivered for disposal.

• Compositional analysis of samples of MSW should be undertaken to provide data on the types and quantities of materials in the waste. Materials suitable for recovery and recycling could then be identified.

• The local councils implementing bring systems should be encouraged to maintain records on the quantities of material collected, frequency of collection, prices obtained from the sale of these materials and market outlets.

Port Wastes

• Given that most of these wastes are disposed of to the Maghtab landfill deliveries of these wastes should be captured at the landfill site in the same way that other waste inputs are recorded. This approach is likely to generate the best data in the short-term.

• Introduce simple procedures at the off-site incineration unit to record all deliveries of waste including source, type by visual inspection of waste materials, container used, estimate of weight.

• Surveys could be conducted at the port areas, observing types and general weights of loads being collected for disposal and waste movements into and out of the port area.

• Undertake compositional analysis of samples of the solid wastes taken from vessels, dry dock and port side areas to understand better the composition of these wastes and their potential for recovery.

Summary of Recommendations presented

in Preliminary Report

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• Undertake weighings of dry wastes collected from a sample of aircrafts (short and long haul flights). Waste production per passenger could be calculated and used to provide an annual estimate of aircraft wastes based on total flight movements.

• Undertake weightings of a sample of the skips collected from the terminal and workshop areas. These weights could then be extrapolated based on the number of collections to provide an annual estimate. Again, as most of the landside wastes are disposed at Maghtab landfill this data could also and be captured at the landfill site in a similar way as proposed for other waste types.

• Introduce simple procedures at the on-site incineration unit to record all deliveries of waste including source (aircraft or food preparation), waste types based on a visual inspection of waste materials, containers used, estimate of weight.

• Encourage Corinthia Caterers to continue with sample weighing programme for all food wastes until a full 12-months of data is obtained. This should enable variations in waste production to be established.

• Undertake compositional analysis of samples of all the various elements of this waste stream to determine recovery potential.

Health Care Wastes

• Sample surveys at all major health care centres should be undertaken to observe the type and weight of wastes generated. Using this weight data, estimates could then be made of waste generation per hospital bed (differentiating if feasible between medical and surgical beds). These estimates could then be compared with data available for other similar jurisdictions to Malta.

• A strict trial segregation scheme should be introduced at a major health care centre to provide a true understanding of the different wastes being generated, and hence enable the need for more specialised treatment facilities to be more accurately assessed. Segregation systems for health care wastes are discussed further under Recommendation 2 - Waste Classification Systems.

• Where health care wastes are being disposed at on-site incineration units records of all waste deliveries should be maintained and supported by sample weighing

programmes.

• Again, given that some health care wastes are disposed at the Maghtab Landfill deposits of these wastes can be recorded at the landfill. This will also provide some data on movements of health-care wastes.

Abattoir Wastes

• To improve the reliability of this data it is recommended that a sample of skips are weighed from both the Malta and Gozo abattoirs. Annual estimates could then be extrapolated for each facility based on the weight per skip and number generated.

• Once again, as most of the wastes from the Malta plant are now disposed at the Maghtab Landfill the weight of vehicle loads could be recorded at the landfill.

Summary of Recommendations presented

in Preliminary Report

E

Recommendation 2: To provide Guidance on the Definitions of Wastes

including Sub-Classifications for all Waste Streams

Waste Classification Scheme

• Whilst waste types are described in the State of the Environment report a standard waste classification scheme for Malta needs to be adopted and guidance provided on the definition of all waste types. This does not need to be a complicated system, but it does need to be adopted by all government departments and relevant agencies. A common waste classification system is important with respect to data collection.

Health care wastes

• In particular, a better system of classifying health care wastes is required to be implemented immediately as it has implications for waste segregation and

collection procedures at health care facilities. It has been suggested that a system based on the UK Health & Safety Commission be established (Chapter 5), but other classification systems could be considered. The UK system classifies clinical waste into five categories and specifies the preferred disposal route for each category. Waste to be disposed of in a particular manner would then be

segregated into colour coded containers that would be standard for all health care facilities in Malta. These containers would only be used for the disposal of clinical wastes and not for other wastes generated at health care facilities. The waste classification system therefore needs to be practical and relate directly to the disposal options for the segregated wastes. This approach needs to be developed and implemented by the Ministry of Health with support from EPD.

Recommendation 3: To introduce Improved Management Practices at all

Waste Disposal Facilities

Landfill Sites

• Ensure all waste inputs to the sites are controlled. This requires adequate manning of the site (at least 2 staff); that the facility is secure to prevent unauthorised deposits and the general public from entering the site (installation of fencing/gates), and all waste inputs should be recorded on arrival at the site (as per Recommendation 1).

• All wastes should be deposited, compacted and covered preferably on a daily basis to control odours, prevent wind blown litter, and to improve upon the general

appearance of the site

• Consideration may need to be given to the erection of litter nets or screens

• Handling procedures must be introduced for special wastes, particularly health care wastes and abattoir wastes. Based on recognised best practice these should include;

- pre-notification of delivery of these wastes should be given so that preparations can be made on site

Summary of Recommendations presented

in Preliminary Report

E

- delivery of these wastes should be mid-morning so that other wastes can be used as cover

- these wastes should be buried at the front of the tipping face and should be immediately covered by other wastes

• Effort should be made to extinguish the underground fires otherwise they could continue to smoulder for years and present a serious threat to the environment as well as a potential hazard to the local population. This can be done by injecting water onto the fire, or by isolating the fire by digging a trench and then flooding it with water.

• Environmental monitoring controls for surfacewater, groundwater and landfill gas should be implemented within and outwith the site boundaries to determine the extent, if any, of any pollution impacts from site operations. Appropriate remediation measures may then need to be implemented.

Working Plans should be prepared for all Operational Sites

• Working plans should be required for all existing waste disposal facilities, and in the future for all new waste disposal facilities. These plans should document the operational practices and administrative procedures which will be implemented at the site including hours of operation, waste acceptance procedures, waste deposit procedures, procedures for handling difficult or special wastes, health and safety procedures, environmental monitoring programmes, etc. Preparation of a Working Plan should be conditional upon obtaining a licence or permit to operate a facility and would be additional to requirement to obtain planning permission.

Recommendation 4: Consideration should be given to the Development

and Implementation of ‘Duty of Care’ Provisions

Duty of care provisions are designed to ensure that producers of waste take responsibility for ensuring that the waste they produce is handled and disposed in the proper manner. It can be applied to any person who imports, produces, carriers, keeps, treats or disposes of certain types of waste’. It requires ‘reasonable methods’ to be taken to fulfil four key requirements:

1. Preventing the unlawful deposit, storage or treatment of waste - practically, this involves gaining assurances that waste will be disposed at an approved (licensed) facility. 2. Preventing the escape of wastes either by accident or intentional tampering - secure

packaging and labelling of wastes will be essential to achieve this.

3. Waste must be transferred to an ‘authorised person’ - for carriers, registration with the appropriate Agency (EPD) will be required, and all waste management facilities must be licensed.

4. Provision of adequate written description of the waste. Type, quantity and special handling requirements of the material and the names and addresses of transferors and transferees should be included on transfer notes accompanying the waste. This facilitates safe and effective management of the wastes.

Summary of Recommendations presented

in Preliminary Report

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In the UK statutory exceptions to the duty of care exist, notably storage of domestic waste by householders. Wastes such as agricultural, mining, explosive and radioactive materials are also excluded. Breach of the duty of care is a criminal offence punishable with an unlimited fine in the Crown Court and up to a £5,000 fine before the magistrates. It therefore can provide a powerful new tool for the waste management regime. Whilst it may not be practical to introduce these measures within 12 months preparatory work can be started during this period. Specific proposals include:

Waste Producers

• Currently there is no requirement on industrial, commercial or institutional waste producers to take responsibility for the proper collection and disposal of the wastes that they produce. Responsibility should be placed on all waste producers to ensure that they only engage the services of a licensed waste carrier and that their wastes are being disposed of at official waste disposal sites. Evidence of all waste movements would be supported by a waste transfer note.

Waste Carriers

• The requirement for contractors /carriers delivering wastes to the Maghtab landfill to be registered should be extended to all waste carriers i.e. only authorised carriers would be able to collect and transport waste on a commercial basis.

Waste Disposal Facilities

• All waste disposal facilities should be licensed by the EPD. The waste

management licence should set out the conditions which apply to the operation of the facility and should include the requirement for the preparation of a Working or Operational Plan (refer Recommendation 3). Inspection and enforcement would be the responsibility of the EPD.

Recommendation 5: The Existing Landfill Charging Scheme should be

Reviewed

• Consistent with the ‘principle of polluter pays’ the Government should review its landfill charging scheme. Current landfill charges are very low compared with other jurisdictions and do not provide an incentive for waste producers to consider

alternative options of dealing with their wastes. As long as charges remain low then alternative options will appear costly in comparison. In due course the introduction of wider scale charging may need to be linked to the development of new facilities, but in the meantime the government should continue to enforce its charging scheme at the Maghtab landfill and introduce it at the Gozo landfill.

Recommendation 6: The Development of Privately Operated Inert

Waste Disposal Sites should be Encouraged

• The Government should review the bond arrangements which currently restrict the diversion of inert wastes from public landfilling operations to private sector sites. This would reduce pressure on capacity at the Maghtab landfill in particular, and

Summary of Recommendations presented

in Preliminary Report

E

would provide more local provision of sites with the benefit of reducing movements of these wastes, provide a means of restoring former quarry sites, and help prevent further increases in fly tipping and illegal disposal practices.

• Operations at these sites would need to be regulated by the EPD, and in particular controls would need to be implemented to ensure inert wastes only were being deposited.

Recommendation 7: Identify a Site for an Engineered Landfill Facility on

Malta

• A clear need for new facilities to meet Malta’s future waste management needs has been identified in this Report. The National Waste Management Strategy being developed by the EPD will provide further guidance on the objectives of waste management and hence the principles to be adopted in selecting future waste management options. However, irrespective of the preferred solution(s) there will remain a need for suitably engineered landfill capacity for the disposal of residues from waste management treatment processes and for those wastes which cannot be handled and treated in any other way. The Planning Authority has initiated a search for potential sites and this should be continued as a matter of priority. In many jurisdictions the development of new landfill sites from site selection through to securing all necessary proposals can take several years.

Recommendation 8: Steps should be taken to raise the Awareness of

the Public on Waste Management Issues

• Public awareness of waste management is low, except in the vicinity of existing waste disposal sites where opposition to waste management activities have been expressed. A public education and awareness raising programme needs to be developed in support of the establishment of any future recovery and recycling schemes. This should highlight the extent of the problem and highlight the benefits of minimising, separating and recycling wastes.

• A public consultation programme will conducted during the preparation of the Waste Management Subject Plan. This will raise the profile of waste management in the public arena and obtain the publics view on issues addressed within the plan.