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            october 14, 2019

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Containerised waste: so much can go wrong


Containers carrying waste shipments can suffer structural damage due to improper stowage practices at the loadout point or become unusable due to tainting from a particular cargo’s malodorous properties. Ports may turn down cargoes of contaminated green waste. Unbalanced loads may cause vehicles to roll over during road transportation. 
Shipments may be rejected at the port of discharge due to incorrect or incomplete documentation. Shippers and receivers may fail to take timely and appropriate measures to mitigate problems arising from incidents and may even abandon waste cargo, leaving the container operator to arrange disposal or return the cargo expensively to origin.  
There is plenty which can go wrong. The Perils of Waste Shipments in Freight Containers, produced this month by the UK P&I Club under the Carefully To Carry banner, highlights the problems and summarises the legislative framework surrounding the trade.  
Many countries receive hazardous waste as a welcome source of business with at least 8.5 million tonnes shipped internationally each year. The transboundary movements of various wastes and their volumes have increased significantly over the last decade, with recycling the primary spur. Certain types of waste have become more valuable to export, such as electrical and electronic equipment, which is very expensive to recycle or treat in Western Europe.  
Growing manufacturing and industrial activities in southern China and the country’s increased demand for recovered scrap materials have helped expand the trade. Between 2003 and 2007, the waste imported and exported by China – about two-thirds of it plastics----increased from about seven million tonnes to well over 11 million tonnes.  
Since 2006, the rate of increase has slackened considerably. Nevertheless, a vessel loading in the United Kingdom for China may hitherto have had up to 65 per cent of its loaded containers carrying recyclable waste.  
The global economic downturn can be expected to adversely affect the level of international waste shipments. Whatever the volumes, however, political pressures and formal rules to ensure the trade is carried out safely and to high environmental standards will continue and consolidate. That adds up to quite a minefield for the container operator to traverse. 
The Carefully To Carry team of experts point out that the first indication of something untoward with a container load of waste may be on arrival at the loading terminal when it is found damaged. This could well be manifest in roof or sidewall panels bulging outwards beyond their accepted envelope.  
Typical causes include bales of non-uniform size, perhaps incorporating a range of waste products, packed together loosely or indiscriminately. 
It is not always possible to identify the cause of damage from a doorway inspection. This may require attendance at the container’s unpacking, perhaps some distance from the port. 
Classifying waste can be hard as 100 per cent pure waste streams are difficult to produce unless an advance separation process is used. Not all countries have access to the technology. Further, there has been confusion about waste that is not ‘waste’ but is exported as raw material for recycling. This raises questions about disposal routes, treatments and prospective re-use of material.  
The main international legislation governing the carriage of waste in containers is the Basel Convention. Negotiated under the United Nations Environment Programme, it was adopted in 1989 and came into force in 1992. It was originally designed to address the uncontrolled movement and dumping of hazardous wastes, including incidents of illegal dumping in developing nations by developed world parties. Among the 170 member countries, Afghanistan, Haiti and the United States have signed but not ratified it.  
The Convention regulates the movement across international frontiers of hazardous and other wastes. These include paper, paperboard and paper product wastes, plastic, mixed plastic materials and metal or alloy electrical and electronic assemblies.  
Written consent has to be obtained from the states of export, import and transit. The Convention obliges its parties to ensure that hazardous and other wastes are managed and disposed of in an environmentally sound manner. Parties are expected to minimise the generation of waste and the quantities moved across borders and to treat and dispose of it as close as possible to the place of generation.  
“Disposal” embraces operations resulting in final disposal and those which may lead to resource recovery, recycling, reclamation, direct re-use or alternative uses. The Convention addresses 27 categories and 18 waste streams that make hundreds of waste materials.
Annexes list wastes classified as hazardous and subject to control procedures, and other wastes, primarily household, which require special consideration.  
The Convention Secretariat likes to be informed about additional wastes, considered or defined as hazardous wastes under national legislation, and of any requirements concerning their transboundary movement. If a transboundary shipment cannot be completed in accordance with the contract, the exporter must take it back into his state unless alternative arrangements can be made for environmentally sound disposal.  
A major difficulty for container operators is that the client, as the booking party, may not be the originator of the waste. He may well be a consolidator or non vessel operating common carrier who is, in turn, dependent on the quality and nature of the waste supplied by a third party. An operator may have a good relationship with a booking party but if the latter acquires a new supplier, there may be liaison and communication problems. 
According to the UK P&I Club’s Loss Prevention director Karl Lumbers: “Owners need to be careful when accepting shipments and must be alive to the risks involved. Particular attention should be paid to assisting booking clerks with lists of pre-approved shippers and reminders that acceptance of large, one-off shipments from unknown shippers may have unfortunate consequences.    “There is far too much deception and carelessness around on the part of some shippers. In some cases, what is packed leaves much to be desired.” 
Happy to traffic illegally in waste
The Basel Convention is very much concerned with illegal traffic in waste. Typically, this may involve lack of prior notification of a shipment; failing to secure the consent of all states concerned; obtaining consent through falsification, misrepresentation or fraud; disguising material variation between cargo and documentation; or deliberately dumping hazardous or other wastes in contravention of both the Convention and the general principles of international law. 
However, some shippers are happy to break the rules. In preparing The Perils of Waste Shipments in Freight Containers, the UK P&I Club’s Carefully To Carry team checked out a number of incidents. 
*Sixty freight containers containing 1,600 tonnes of waste were seized by the Dutch port authorities. The waste, declared as recovered paper, was on its way to China from the United Kingdom. However, the containers yielded bales of compacted household waste, food packaging and residues, plastic bags, waste wood and textiles. The waste was first transported to Dutch ports by lorry and ferry, where the bales were then transferred into the freight containers.  
*Investigators in Britain, the Netherlands and Indonesia tracked 95 40ft containers carrying household rubbish. Sixty were seized by the Dutch authorities and 15 impounded in Southampton, while 20 reached Indonesia and Malaysia. The exporter was fined US$110,000.  
*A containerised shipment of waste from the UK destined for India had been declared to customs as containing paper. It was opened by enforcement agents who found paper, plastics, wood, metals and textiles contaminated by food wastes. An attempt by the exporters to save US$ 2,500 in fees under the correct procedure landed them with a fine of US$ 20,000. 
*Three container loads of “electrical motors” turned out to be an assortment of electrical motors thrown into the containers with other rubbish which included plastic intermediate bulk containers. 
*One opened container revealed waste paper contaminated with tin cans, some with jagged edges, plastic bottles, plastic bags, pieces of wood and twigs and a complete inflatable rubber mattress. Such a mixture could not be recovered in an environmentally sound manner.
*A container was rejected by ship staff before loading as liquid was leaking from the door seal. When opened, emulsified oil was found on top of the door sill. Two solid plastic type IBCs containing shredded plastic waste, were stowed in the doorway; behind them: shredded plastic waste to about half the height of the container. 
While the import of electronic waste into mainline China is illegal, legislation in Hong Kong appears to provide loopholes, allowing it to enter the country and make its way to scrap yards in China. In particular, the terms ‘reuse’, ‘reprocessing’, ‘recycling’, ‘recovery operations’ and ‘contamination are less rigorously defined.

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