Waste Storage

Do you need to register in terms of the ‘National Norms and Standards for Storage of Waste, 2013’? (GN926)

* Are you storing more than 100m3 of general waste? i.e. The equivalent volume of 10 metres wide, 10 metres wide and one metre high. ‘General waste’ means waste that is not a risk to human health (i.e. is not ‘Hazardous waste’). Most commercial recycling facilities are storing more than this volume and thus must register. If your waste is hazardous then a volume more than 80m3 must be registered. A storage area of more than 500m2 of waste tyres must be registered (i.e. anything bigger than a square of 23 metres long and 23 metres wide) (GN921, Category C). It does not make any difference whether your waste storage area is in a building or outdoors.

* The ‘Norms and Standards for Storage of Waste‘ require registration including provision of information to the environmental authority within 90 days prior to construction taking place. In the Western Cape, this authority is the Department of Environment Affairs and Development Planning (DEA&DP). Ongoing safety and management requirements are also specified, which are much stricter for liquid waste and hazardous waste.

* In the Western Cape, most pollution generating and waste processing facilities are also required to register on the Integrated Pollutant and Waste Information System (IPWIS). The Department of Environmental Affairs and Development Planning (DEA&DP) has specified a list of pollutants for which registration is required. Nevertheless, the department may add to this list of pollutants, and since registration is quick and simple, it advisable for any industrial activity that may generate pollution to register.

* Waste facilities over certain thresholds, are also required to get an Environmental Authorisation in terms of GN 926 prior to commencement. This may require a Basic Assessment or Environmental Impact Assessment process depending on the size. For example, a recycling facility that has an operational area of more than 500m2 (i.e. bigger than a square 23m long and 23m wide excluding recycling at the same factory) must do a ‘Basic Assessment’ process. This process is expensive, involves consulting the public and report writing, and can take six months to a year to complete depending on the issues and complexity. Commencement of an activity that requires Environmental Authorisation, without such authorisation carries serious legal penalties, even if the activity is a benefit to the environment. If you are thinking about opening or expanding any form of waste facility, it is important to check the legal requirements.

This Plain English summary of requirements relevant to the storage of waste should not substitute for professional advice specific to your waste facility. Rosenthal Environmental can assist you in clarifying your waste-related environmental compliance requirements, and with complying in the Western Cape Province. Contact us at 082 6768966.

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Key relevant waste regulations are:
* Government Notice 921, the ‘List of of Waste Management activities that have or are likely to have a detrimental effect on the environment‘, promulgated in terms of the National Environmental Management Waste Act, Act 59, 2008.
* Government Notice 926 ‘National Norms and Standards for the Storage of Waste‘, promulgated in terms of the National Environmental Management: Waste Act, Act 59 of 2008.

* “Hazardous waste” means any waste that contains organic or inorganic elements or compounds that may, owing to the inherent physical, chemical or toxicological characteristics of that waste, have a detrimental impact on health and the environment and includes hazardous substances, materials or objects within the business waste, residue deposits and residue stockpiles. All other waste is classified as ‘general waste’ in the NEM:Waste Amendment Act, 2014.

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