Toxic Fish and Sewer Surfing
The ‘new’ trade waste policy – how new?
In 1988 the Board introduced a ‘new’ trade waste policy. The Board claims the new policy represents a radical change in approach. However, it is based on a similar philosophy to the old one. It attempts to provide a service to industry whilst limiting the contamination of discharges by charging on the basis of how concentrated a waste stream is rather than having absolute limits or effluent standards:
The Policy aims to encourage industry to improve pretreatment of wastes, towards ‘domestic’ quality. At the same time, the Board will be providing a commercially oriented liquid waste disposal service to industry, and recovering some of the special treatment costs that the discharge of pollutants imposes on the whole community (Sydney Water Board, 1988).
The Board has stated that the sewerage system is the most appropriate method of disposing of many industrial liquid wastes – offering the community an acceptable method of controlling pollution and offering industry a cheaper system than if it had to treat its own wastes.
The new trade waste policy aims to replace the emphasis on ‘control’ with one of ‘commitment’. The monitoring and policing of industrial discharges is said to be difficult. The installation of automatic measuring devices and the employment of large numbers of inspectors are said to be too expensive. Rather than policing it, the new policy aims at encouraging the cooperation of industry. It is hoped that businesses can be encouraged, through financial incentives, to manage their wastes as carefully as they do their production processes. Each company is being required to institute its own monitoring programme of sampling and testing, which will be audited by the Board.
The Municipal Officers’ Association spokesman, Tony Morrison, pointed out in early 1989 that the number of inspectors had been reduced from 37 to 22 in 15 months. He also said that whereas previously they had covered 24 hours, so as to catch night-time dumpers, they now worked office hours only, finishing work at 4 p.m.
The publication of this information and a spate of very visible illegal dumping have since forced the government and the Board to promise to employ more trade waste inspectors. The trade waste inspectors who lost their jobs were skilled plumbers, people who were able to go to factories and spot anything suspicious. It has been claimed that the people who have replaced them are white-collar workers who are dealing with the accounting and the commercial side of the trade waste agreements rather than trying to catch companies cheating.
Waste quality targets are being negotiated with each firm. Under this system, if the polluter is able to install treatment equipment for a lower cost than they would otherwise have to pay to the Water Board to discharge their untreated wastes then there is a financial incentive to do so. In other words, the firm has a choice between reducing its toxic waste stream or paying the Board to use the environment for disposal. Is this a choice that industry should have?
Charges will still be based on concentrations of contaminants in the effluent entering the sewerage system. The more concentrated the pollutants in a firm’s discharge, the more it will be charged. Strength charges will be at higher rates for higher strength waste. So the Board is providing an incentive for cheating, because it asks industry to monitor the strength of its waste and charges higher rates for higher strength discharges.
The standards in the new trade waste policy do not represent absolute limits on what will be allowed into the sewers, since there is provision to charge for concentrations above the standards. These standards are little more than a pricing mechanism and whether the Board uses them as upper limits for discharge is up to their discretion at the time, presumably after negotiation with businesses concerned.
Moreover, industries are charged less for putting a certain volume of restricted substances down the sewer if that volume is more dilute. Mercury for example, can be put into the sewers for between $5 and $200/kg depending on how concentrated it is. The charges are based on 90 percentile concentrations, so that 10 per cent of the time discharges can be extremely concentrated without attracting charges. This would conveniently allow for occasional discharges that may occur, for example, when vats or rinsing tanks are washed out. This emphasis in the Board’s trade waste policy on levels of dilution can be traced back to the SPCC guidelines, which are in terms of dilution. The SPCC regulates restricted substances by stating maximum concentrations. Similarly, the harm posed to sewers, workers and equipment can be minimised by ensuring high levels of dilution. For these reasons the Board is more concerned about concentrations of toxic substances being discharged than total quantities.
Previously in this chapter:
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