Step 1: Consult with key industries and associations: Government officials should meet with representatives of industries that are likely to own large quantities of products, articles or wastes consisting of, containing or contaminated with POPs, and with former producers and distributors. Since chemical, agricultural, electrical, and other large industries probably own or have knowledge about a large percentage of the country’s total amount of POPs, they should be consulted first. Government officials should also meet with non-governmental organizations to seek their assistance.
Step 2: Train personnel: Government staff members who are responsible for the inventory should be trained in all aspects of products, articles and wastes. The key training elements should include the identification of products, articles and wastes consisting of, containing or contaminated with POPs; audits and inspections; health and safety; and procedures for setting up and maintaining inventories.
Step 3: Conduct several trial audits: Several facilities should be visited by government personnel. These visits should serve three purposes. First, they will familiarize government staff with the inventory process and actual on-site conditions. Second, they will serve as another form of consultation with industry. Third, they will produce some inventory information that can be used as trial data for the development of the national inventory.
Step 4: Develop policy or regulations requiring owners to report POPs: A draft policy or regulation regarding the tracking of POPs and reporting to the Government for inventory purposes should be developed. The policy or regulation should require initial reporting by a certain date and subsequent reporting when changes to inventories are made by owners or when disposal occurs. The reporting requirement should request specific information for each distinct inventory item, including:
(a) Name or description of product, article or waste;
(b) Physical state (liquid, solid, sludge, gas);
(c) Weight of container or equipment (if applicable);
(d) Weight of material consisting of, containing or contaminated with POPs;
(e) Number of similar containers or pieces of equipment;
(f) Concentration of POPs in the product, article or waste;
(g) Other hazards associated with the material (e.g., combustible, corrosive, flammable);
(i) Owner information;
(j) Identifying labels, serial numbers, marks, etc.;
(k) Date entered inventory;
(l) Date removed from inventory and fate (if applicable).
Step 5: Implement the plan: Before implementing the requirement to report inventories, a national inventory database should be set up. The Government’s central inventory should be kept up to date as new information comes in. Governments can assist owners by providing information and advice. Site inspections should help ensure that the inventory information is correct.24
In addition, it should be noted that the 2003 Protocol on Pollutant Release and Transfer Register to the 1998 United Nations Economic Commission for Europe (UNECE) Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters includes provisions pertaining to the inventories that may be applicable to POPs.
E. Sampling, analysis and monitoring
Sampling, analysis and monitoring are critical components in the management of wastes consisting of, containing or contaminated with POPs and should be given high priority with respect to both capacity-building in developing countries and implementation. Sampling, analysis and monitoring should be conducted by trained professionals in accordance with a well-designed plan and using internationally accepted or nationally approved methods, carried out using the same method each time over the time span of the programme. They should also be subjected to rigorous quality assurance and quality control measures. Mistakes in sampling, analysis or monitoring, or deviation from standard operational procedures, can result in meaningless data or even programme-damaging data. Each Party, as appropriate, should therefore ensure that training, protocols and laboratory capability are in place for sampling, monitoring and analytical methods and that these standards are enforced.
Because there are numerous reasons to sample, analyse and monitor, and also because there are so many different physical forms of waste, there are hundreds of different methods that can be used for sampling, analysis and monitoring. It is beyond the scope of this document to discuss even a few of the actual methods. In the next three sections, however, the key points of sampling, analysis and monitoring are considered.
For information on good laboratory practices the OECD series (OECD, various years) may be consulted; on general methodological considerations, the guidance document for the Global Monitoring Programme on POPs (UNEP 2004a) may be used; and further information on POPs analysis may be obtained from the UNEP/Global Environment Facility (GEF) project on capacity needs for analysing POPs at www.chem.unep.ch/pops/laboratory/default.htm.
The overall objective of any sampling activity is to obtain a sample which can be used for the targeted purpose, e.g., site characterization, compliance with regulatory standards or suitability for proposed treatment or disposal. This objective should be identified before sampling is started. It is indispensable for quality requirements in terms of equipment, transportation and traceability to be met.
Standard sampling procedures should be established and agreed upon before the start of the sampling campaign (both matrix- and POP-specific). Elements of these procedures include the following:
(a) The number of samples to be taken, the sampling frequency, the duration of the sampling project and a description of the sampling method (including quality assurance procedures put in place, e.g., field blanks and chain-of-custody);
(b) Selection of location or sites and time of sample-taking (including description and geographic localization);
(c) Identity of person who took the sample and conditions during sampling;
(d) Full description of sample characteristics – labelling;
(e) Preservation of the integrity of samples during transport and storage (before analysis);
(f) Close cooperation between the sampler and the analytical laboratory;
(g) Appropriately trained sampling personnel.
Sampling should comply with specific national legislation, where it exists, or with international regulations. In countries where regulations do not exist, qualified staff should be appointed. Sampling procedures include the following:
(a) Development of a standard operational procedure (SOP) for sampling each of the matrices for subsequent POPs analysis;
(b) Application of well-established sampling procedures such as those developed by the American Society for Testing and Materials (ASTM), the European Union, the United States Environmental Protection Agency (EPA) and the Global Environment Monitoring System (GEMS);
(c) Establishment of quality assurance and quality control (QA/QC) procedures.
All these steps should be followed for a sampling programme to be successful. Similarly, documentation should be thorough and rigorous.
Types of matrices typically sampled for POPs include solids, liquid and gases:
Leachate from dumpsites and landfills;
Liquid collected from spills;
Water (surface water, drinking water and industrial effluents);
Biological fluids (blood, in the case of workers’ health monitoring);
(i) Stockpiles, products and formulations consisting of, containing or contaminated with POPs;
(ii) Solids from industrial sources and treatment or disposal processes (fly ash, bottom ash, sludge, still bottoms, other residues, clothing, etc.);
(iii) Containers, equipment or other packaging materials (rinse or wipe samples), including the tissues or fabric used in the collection of wipe samples;
(iii) Soil, sediment, rubble, sewage sludge and compost;
(i) Air (indoor).
In environmental and human monitoring programmes, both biotic and abiotic matrices may be included:
(a) Plant materials and food;
(b) Human breast milk or blood;
(c) Air (ambient, wet or dry deposition or, possibly, snow).
Analysis refers to the extraction, purification, separation, identification, quantification and reporting of POPs concentrations in the matrix of interest. To obtain meaningful and acceptable results, the analytical laboratory should have the necessary infrastructure (housing) and proven experience with the matrix and the POP (e.g., successful participation in international intercalibration studies). Accreditation of the laboratory according to ISO 17025 or other standards by an independent body is an important aspect. Indispensable criteria for obtaining high-quality results include:
Specification of the analytical technique;
Maintenance of analytical equipment;
Validation of all methods used (including in-house methods);
Training of laboratory staff.
Typically, POPs analysis is performed in a dedicated laboratory. For specific situations, test kits are available that can be used in the field for screening purposes.
For laboratory POPs analysis, there is no one analytical method available. Methods of analysing the various matrices for POPs have been developed by ISO, the European Committee for Standardization (CEN), EPA, AOAC and ASTM. Annex III lists some examples. Most in-house methods are variations of these, and after validation such in-house methods are also acceptable.
In addition, procedures and acceptance criteria for handling and preparation of the sample in the laboratory, e.g., homogenization, should be established.
The individual steps in the analytical determination include:
Extraction, e.g., by Soxhlet, accelerated solvent extraction (ASE), liquid-liquid, etc.;
Purification, e.g., by column chromatography or with Florisil. Purification should be efficient enough so that chromatographic retention is not influenced by the matrix;
Separation by capillary gas chromatography (HRGC), which will provide sufficient separation of analytes;
Identification by suitable detectors such as an electron capture detector (ECD) or a mass selective detector (MSD), or by either low-resolution mass spectrometry or high-resolution mass spectrometry (LRMS or HRMS);
Quantification according to internal standard methodology (for reference, see UNEP 2004a, UNEP, 2006);
Reporting in accordance with regulation(s).
In paragraph 2 (b) of its Article 10 (“International Cooperation”), the Basel Convention requires Parties to “cooperate in monitoring the effects of the management of hazardous wastes on human health and the environment”. In paragraph 1 of its article 11, the Stockholm Convention requires Parties to encourage and/or undertake appropriate monitoring pertaining to the POPs. Monitoring programmes should provide an indication of whether a hazardous waste management operation is functioning in accordance with its design, and should detect changes in environmental quality caused by the operation. The information from the monitoring programme should be used to ensure that the proper types of hazardous wastes are being managed by the waste management operation, to discover and repair any damage and to determine whether an alternative management approach might be appropriate. By implementing a monitoring programme, facility managers can identify problems and take appropriate measures to remedy them.26
F. Handling, collection, packaging, labelling, transportation and storage
Handling, collection, packaging, labelling, transportation and storage are critically important steps as the risk of a spill, leak or fire (for example, in preparation for storage or disposal) is at least as great as at other times.
For transport and transboundary movement of hazardous wastes, the following documents should be consulted to determine specific requirements:
Basel Convention: Manual for Implementation (UNEP, 1995);
International Maritime Dangerous Goods Code (IMO, 2002);
International Civil Aviation Organization (ICAO) Technical Instructions for the Transport of Dangerous Goods;
IATA Dangerous Goods Regulations and the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations (Orange Book).
For the following sections 1–6, detailed information can be obtained from “Destruction and Decontamination Technologies for PCBs and other POPs wastes under the Basel Convention, a Training Manual for Hazardous Waste Project Managers, Volumes A and B” by the Secretariat of the Basel Convention (UNEP, 2002).
Wastes consisting of, containing or contaminated with POPs above the low POP contents referred to in section III.A should be managed as hazardous waste, to prevent spills and leaks leading to worker exposure, releases to the environment and exposure to the community.
The main concerns when handling wastes consisting of, containing or contaminated with POPs are human exposure, accidental release to the environment and contamination of other waste streams with POPs. Such wastes should be handled separately from other waste types in order to prevent contamination of other waste streams. Recommended practices for this purpose include:
(a) Inspecting containers for leaks, holes, rust or high temperature, and appropriate repackaging and relabelling as necessary;
(b) Handling wastes at temperatures below 25°C, if possible, because of the increased volatility at higher temperatures;
(c) Ensuring that spill containment measures are adequate and would contain liquid wastes if spilled;
(d) Placing plastic sheeting or absorbent mats under containers before opening them if the surface of the containment area is not coated with a smooth surface material (paint, urethane or epoxy);
(e) Removing liquid wastes either by removing the drain plug or by pumping with a peristaltic pump and suitable chemical-resistant tubing;
(f) Using dedicated pumps, tubing and drums, not used for any other purpose, to transfer liquid wastes;
(g) Cleaning up any spills with cloths, paper towels or absorbent;
(h) Triple rinsing of contaminated surfaces with a solvent such as kerosene;
(i) Treating all absorbents and solvent from triple rinsing, disposable protective clothing and plastic sheeting as wastes containing or contaminated with POPs when appropriate.
Staff should be trained in the correct methods of handling wastes consisting of, containing or contaminated with POPs.