Sekitar Synergy Sdn Bhd: SW List & Law

Note: The rule of the thumb; wastes need to be segregated by prioritizing the 3R, that is in view of extending its life-cycle as much as possible before rendering it useless! This list may only be applicable to industrial, services and commercial sectors, but, at home we are now subscribing to the new law - Solid Waste and Public Cleansing Management Act, 2007 (Act 672). Remember, 'our wastes' were once our treasured environmental resource which have undergone 'humanized' transformation into products for our life-styles. However, by virtue of their 'changed' properties and characteristics as 'products' they are not readily acceptable to the environment.

The environment can't assimilate their current form. Their entry into the environment simply means pollution. So, urge the authorities to be more pro-active in facilitating the public to comply to this new law - not just carry the whip to command and control! I've already explained this grievance in my page named 'My Platform'. Anyway, I hope this list would simplify lives of many who may need to justify their SW classification. Cheerio.

The Scheduled Waste List

based from the FIRST SCHEDULE (Regulation 2) of The Environmental Quality (Scheduled Waste) Regulations, 2005 - a subsidiary regulation of the Environmental Quality Act, 1974.

SW 1 Metal and metal-bearing wastes

SW 101 Waste containing arsenic or its compound

SW 102 Waste of lead acid batteries in whole or crushed form

SW 103 Waste of batteries containing cadmium and nickel or mercury or lithium

SW 104 Dust, slag, dross or ash containing arsenic, mercury, lead, cadmium,

chromium, nickel, copper, vanadium, beryllium, antimony, tellurium, thallium

or selenium excluding slag from iron and steel factory

SW 105 Galvanic sludges

SW 106 Residues from recovery of acid pickling liquor

SW 107 Slags from copper processing for further processing or refining containing

arsenic, lead or cadmium

SW 108 Leaching residues from zinc processing in dust and sludges form

SW 109 Waste containing mercury or its compound

SW 110 Waste from electrical and electronic assemblies containing components

such as accumulators, mercury-switches, glass from cathode-ray tubes and

other activated glass or polychlorinated biphenyl-capacitors, or contaminated

with cadmium, mercury, lead, nickel, chromium, copper, lithium, silver,

manganese or polychlorinated biphenyl.

'Contactor Switch'

SW 2 Wastes containing principally inorganic constituents which may

contain metals and organic materials

SW 201 Asbestos wastes in sludges, dust or fibre forms.

SW 202 Waste catalysts

SW 203 Immobilized scheduled wastes including chemically fixed, encapsulated,

solidified or stabilized sludge.

A summarized process flow of a nickel

electroplating process commonly found in

the surface treatment of metals such as

exhaust-pipes. An array of SW which are

mostly hazardous if not toxic are generated.

WWTP stands for Waste Water Treatment

Plant where treated effluent are discharged

based on their respective limits set by the

law. Nonetheless, sludge, in this case in the

form of 'filter-cake' released from the sludge

filter press generates SW 204 or SW 412

depending on its composition.

SW 204 Sludges containing one or several metals including chromium, copper,

nickel, zinc, lead, cadmium, aluminium, tin, vanadium and beryllium

SW 205 Waste gypsum arising from chemical industry or power plant

SW 206 Spent inorganic acids

SW 207 Sludges containing fluoride

Picture: Sludge cake originating from the Filter Press De-watering Equipment that contain an array of Heavy Metals which were coagulated and settled as sludge in an effluent treatment plant. Coded as SW 204 as it contains copper and a few other metals. They are being sent to a licensed Off-Site Recovery Facility nearby that is able to extract Copper and as a re-generated raw material for a niche market in the region. Its export to the a buyer in another country is subscribing to the BASEL Convention, therefore, a plethora of protocols between the two parties and their respective nations to comply with prior its shipment.

SW 3 Wastes containing principally organic constituents which may contain

metals and inorganic materials

SW 301 Spent organic acids with pH less or equal to 2 which are corrosive or

hazardous.

SW 302 Flux waste containing mixture of organic acids,

solvents or compounds of

ammonium chloride.

Picture: Spent or used varnish in the form of enamel used in the
production of electrical wires; probably classified as SW 417 or
418 depending on its justified compositional and TCLP analysis.

SW 303 Adhesive or glue waste containing organic

solvents excluding solid polymeric

materials

SW 304 Press cake from pretreatment of glycerol soap lye

Picture: Spent or used lubricating and hydraulic oil frequently found in motor workshops, construction sites, plant maintenance warehouse, etc. However, there are recyclers whose business is recycling these items and licensed by the DOE Malaysia. They are probably classified as SW 305 or 306 depending on its justified composition.

SW 305 Spent lubricating oil

SW 306 Spent hydraulic oil

SW 307 Spent mineral oil-water emulsion

SW 308 Oil tanker sludges

SW 309 Oil-water mixtures such as ballast water

SW 310 Sludge from mineral oil storage tank

SW 311 Waste oil or oily sludge

SW 312 Oily residue from automotive workshop, service station, oil or grease

interceptor

SW 313 Oil contaminated earth from re-refining of used lubricating oil

SW 314 Oil or sludge from oil refinery plant maintenance operation

SW 315 Tar or tarry residues from oil refinery or petrochemical plant

SW 316 Acid sludge

SW 317 Spent organometallic compounds including tetraethyl lead, tetramethyl lead

and organotin compounds

SW 318 Waste, substances and articles containing or contaminated with

polychlorinated biphenyls (PCB) or polychlorinated triphenyls (PCT)

SW 319 Waste of phenols or phenol compounds including chlorophenol in the form of

liquids or sludges.

SW 320 Waste containing formaldehyde

SW 321 Rubber or latex wastes or sludge containing organic solvents or heavy metals

SW 322 Waste of non-halogenated organic solvents

SW 323 Waste of halogenated organic solvents

SW 324 Waste of halogenated or unhalogenated non-aqueous distillation residues

arising from organic solvents recovery process.

SW 325 Uncured resin waste containing organic solvents or heavy metals including

epoxy resin and phenolic resin.

SW 326 Waste of organic phosphorus compound

SW 327 Waste of thermal fluids (heat transfer) such as ethylene glycol

Picture: Used and empty plastic chemical containers which still has a small amount of its contents' residues. They are probably classified as SW 409 if its residual content is not removable. This classification still applies if they were containers of different kinds of chemicals. However, it was found that some contractors insisted on using codes such as SW421 and SW422 in order to 'simplify matters' in favour of their license specifications.

SW 4 Wastes which may contain either inorganic or organic constituents

SW 401 Spent alkalis containing heavy metals

SW 402 Spent alkalis with pH more or equal to 11.5 which are corrosive or hazardous

SW 403 Discarded drugs containing psychotropic substances or containing

substances that are toxic, harmful, carcinogenic, mutagenic or teratogenic

SW 404 Pathogenic wastes, clinical wastes or quarantined materials

SW 405 Waste arising from the preparation and production of pharmaceutical product

SW 406 Clinker, slag and ashes from scheduled wastes incinerator.

SW 407 Waste containing dioxins or furans.

SW 408 Contaminated soil, debris or matter resulting from cleaning-up of a spill of

chemical, mineral oil or scheduled wastes

SW 409 Disposed containers, bags or equipment contaminated with chemicals,

pesticides, mineral oil or scheduled wastes.

Picture: These are commonly found in almost all industrial and services activities. They may consist of contaminants like lube oil, hydraulic oils, paint, thinner, solvents, varnish, coolants, sludge, pigments, etc. that are rendered as Scheduled Waste (SW). They are classified as SW 410. As an environmental-friendly practice, they are commonly 'disposed' to a licensed off-site recyclers who technically washes these fabric rags and gloves to a cleaner state. Some are being sold as used rags and gloves while others are returned to their respective waste generators who sent them. However, another environmental burden splashes out of these recyclers' operations i.e. industrial effluent. In most legal circumstances, since their waste wash waters consists of heavy metals or trace metals like Hg, Cd, Cr6+, As, CN, Pb, Cr3+, Mn, Ni and Sn, where their absence is a doubt by experience, are rendered as Industrial Effluent. Hence, these recycling facilities may need to treat their wash waters as they are subscribing to the Environmental Quality (Industrial Effluent) Regulations, 2009. And, chemical treatment costs is expensive. Further, they may generate SW sludge from their Industrial Effluent Treatment's sludge de-watering equipment.
SW 410 Rags, plastics, papers or filters contaminated with scheduled wastes.

SW 411 Spent activated carbon excluding carbon from the treatment of potable water

and processes of the food industry and vitamin production

SW 412 Sludges containing cyanide

SW 413 Spent salt containing cyanide

SW 414 Spent aqueous alkaline solution containing cyanide.

SW 415 Spent quenching oils containing cyanides

SW 416 Sludges of inks, paints, pigments, lacquer, dye or varnish

Picture (above left): This is a bizarre and antiquated specialized ink dispensing system after its final mixing in an ink formulation factory. It produces highly customized ink from high-end ink pigments and refined specification organic solvents. The red pipes and hoses aren't red but tainted with ink leaks! Its cleaning generates organic solvent contaminated with inks - SW 418. These ink-solvent waste flows into receiving drains on the floor and are channelled into an effluent treatment system. Picture (above right): These are used pigments and ink containers probably classified and SW 409, 416, 417 or 421 (depending on its composition and toxicity or convenience according to their respective handlers!) that still contains residues of their original content which are stored prior disposal. They are being disposed to an Off-site Prescribed Premise licensed to incinerate as means of their disposal.
SW 417 Waste of inks, paints, pigments, lacquer, dye or varnish

SW 418 Discarded or off-specification inks, paints, pigments, lacquer, dye or varnish

products containing organic solvent

SW 419 Spent di-isocyanates and residues of isocyanate compounds excluding solid

polymeric material from foam manufacturing process

SW 420 Leachate from scheduled waste landfill

SW 421 A mixture of scheduled wastes

SW 422 A mixture of scheduled and non-scheduled wastes

SW 423 Spent processing solution, discarded photographic chemicals or discarded

photographic wastes.

SW 424 Spent oxidizing agent

SW 425 Wastes from the production, formulation, trade or use of pesticides,

herbicides or biocides

SW 426 Off-specification products from the production, formulation, trade or use of

pesticides, herbicides or biocides

SW 427 Mineral sludges including calcium hydroxide sludges, phosphating sludges,

calcium sulphite sludges and carbonates sludges

SW 428 Wastes from wood preserving operation using inorganic salts containing

copper, chromium or arsenic of fluoride compounds or using compound

containing chlorinated phenol or creosote

SW 429 Chemicals that are discarded or off-specification

SW 430 Obsolete laboratory chemicals

SW 431 Waste from manufacturing or processing or use of explosives.

SW 432 Waste containing, consisting of or contaminated with, peroxides

Picture: It seems that solvent recovery might be a popular resort for cost savings in this region very soon. At the time of this write-up, external recovery centres are still favoured options. On-site recovery of SW is positively stipulated by the law already. Incentives to purchase or develop this technology within the country should alleviate the impact on costs for companies; and resource depletion for the environment.

SW 5 Other wastes

SW 501 Any residues from treatment or recovery of scheduled wastes

(Author: Khalid Mohd Ariff, 19th March 2012, 26th RabiulAkhir 1433.)

What the law says ...

Notification of the generation of scheduled wastes

Regulation 3.

(1) Every waste generator shall, within 30 days from the date of generation of scheduled wastes, notify the Director General of the new categories and quantities of scheduled wastes which are generated.
(2) The notification given under subregulation (1) shall include the information provided in the Second Schedule.

Disposal of scheduled wastes

Regulation 4.

(1) Scheduled wastes shall be disposed of at prescribed premises only.
(2) Scheduled wastes shall, as far as is practicable, be rendered innocuous prior to disposal.

Treatment of scheduled wastes

Regulation 5.

(1) Scheduled wastes shall be treated at prescribed premises or at on‑site treatment facilities only.
(2) Residuals from treatment of scheduled wastes shall be treated or disposed of at prescribed premises.

Recovery of material or product from scheduled wastes

Regulation 6.

(1) Recovery of material or product from scheduled wastes shall be done at prescribed premises or at on-site recovery facilities.
(2) Residuals from recovery of material or product from scheduled wastes shall be treated or disposed of at prescribed premises.

Discussion: Start to 'reuse-reclaim-recycle' on-site!
Waste Generators: Does this law stipulate or state anywhere that a waste generator needs to apply for an 'on-site treatment or recovery or recycling' license?

Application for special management of scheduled wastes

Regulation 7.

(1) A waste generator may apply to the Director General in writing to have the scheduled wastes generated from their particular facility or process excluded from being treated, disposed of or recovered in premises or facilities other than at the prescribed premises or on-site treatment or recovery facilities.

(2) An application under subregulation (1) shall be submitted to the Director General in accordance with the guidelines for special management of scheduled wastes as prescribed by the Director General and shall be accompanied by fee of three hundred ringgit and shall not be refunded.
(3) If the Director General is satisfied with the application made under subregulation (1), the Director General may grant a written approval either with or without conditions.

Responsibility of waste generator

Regulation 8.

(1) Every waste generator shall ensure that scheduled wastes generated by him are properly stored, treated on-site, recovered on-site for material or product from such scheduled wastes or delivered to and received at prescribed premises for treatment, disposal or recovery of material or product from scheduled wastes.

(2) Every waste generator shall ensure that scheduled wastes that are subjected to movement or transfer be packaged, labelled and transported in accordance with the guidelines prescribed by the Director General.

Some uses signboard

Storage of scheduled wastes

Regulation 9.

(1) Scheduled wastes shall be stored in containers which are compatible with the scheduled wastes to be stored, durable and which are able to prevent spillage or leakage of the scheduled wastes into the environment.

(2) Incompatible scheduled wastes shall be stored in separate containers, and such containers shall be placed in separate secondary containment areas.

A poor example

(3) Containers containing scheduled wastes shall always be closed during storage except when it is necessary to add or remove the scheduled wastes.

(4) Areas for the storage of the containers shall be designed, constructed and maintained adequately in accordance with the guidelines prescribed by the Director General to prevent spillage or leakage of scheduled wastes into the environment.

Perimeter drain

(5) Any person may store scheduled wastes generated by him for 180 days or less after its generation provided that −

(a) the quantity of scheduled wastes accumulated on site shall not exceed 20 metric tones; and
(b) the Director General may at any time, direct the waste generator to send any scheduled wastes for treatment, disposal or recovery of material or product from the scheduled wastes up to such quantity as he deems necessary.

Better example

(6) A waste generator may apply to the Director General in writing to store more than 20 metric tonnes of scheduled wastes.
(7) If the Director General is satisfied with the application made under subregulation (6), the Director General may grant a written approval either with or without conditions.

Confined and Contained

Labelling of scheduled wastes

Regulation 10.

(1) The date when the scheduled wastes are first generated, name, address and telephone number of the waste generator shall be clearly labelled on the containers that are used to store the scheduled wastes.

(2) Containers of scheduled wastes shall be clearly labelled in accordance with the types applicable to them as specified in the Third Schedule and marked with the scheduled waste code as specified in the First Schedule for identification and warning purposes.
(3) No person is allowed to alter the markings and labels mentioned in subregulations (1) and (2).
Below: Examples of the SW Labels and its respective types of SW based on hands-on comprehension of its physical and chemical characteristics from its origin. Most are referrals inferred from its compositional, chemical & physical and TCLP analysis. However, these are summarized generalization and specific typing based on its actual 'waste stream audit and analysis' should remain the most reliable and representative coding method. Note: a waste code may bear more than one type of SW Labels!

SW Label recommended for;
SW 204 Sludges containing one or several metals including chromium, copper, nickel, zinc, lead, cadmium, aluminium, tin, vanadium and beryllium(if contains biological microbes from biological treatment plants)

SW 105 Galvanic sludges

SW 431 Waste from manufacturing or processing or use of explosives

SW 432 Waste containing, consisting of or contaminated with, peroxides

SW Label recommended for;
SW 302 Flux waste containing mixture of organic acids, solvents or compounds of ammonium chloride
SW 303 Adhesive or glue waste containing organic solvents excluding solid polymeric materials

SW 305 Spent lubricating oil

SW 306 Spent hydraulic oil

SW 302 Flux waste containing mixture of organic acids, solvents or compounds of ammonium chloride

SW 305 Spent lubricating oil

SW 306 Spent hydraulic oil

SW 307 Spent mineral oil-water emulsion

SW 308 Oil tanker sludges

SW 309 Oil-water mixtures such as ballast water

SW 310 Sludge from mineral oil storage tank

SW 311 Waste oil or oily sludge

SW 312 Oily residue from automotive workshop, service station, oil or grease interceptor SW 314 Oil or sludge from oil refinery plant maintenance operation

SW 322 Waste of non-halogenated organic solvents

SW 323 Waste of halogenated organic solvents

SW 325 Uncured resin waste containing organic solvents or heavy metals including epoxy resin and phenolic resin

SW 417 Waste of inks, paints, pigments, lacquer, dye or varnish

SW 418 Discarded or off-specification inks, paints, pigments, lacquer, dye or varnish products containing organic solvent

SW Label recommended for;
SW 108 Leaching residues from zinc processing in dust and sludges form

SW 201 Asbestos wastes in sludges, dust or fibre forms

SW 202 Waste catalysts (such as molecular sieves)

SW 203 Immobilized scheduled wastes including chemically fixed, encapsulated, solidified or stabilized sludges

SW 205 Waste gypsum arising from chemical industry or power plant

SW 303 Adhesive or glue waste containing organic solvents excluding solid polymeric materials

SW 313 Oil contaminated earth from re-refining of used lubricating oil

SW 314 Oil or sludge from oil refinery plant maintenance operation

SW 315 Tar or tarry residues from oil refinery or petrochemical plant

SW 316 Acid sludge

SW 324 Waste of halogenated or unhalogenated non-aqueous distillation residues arising from organic solvents recovery process

SW 409 Disposed containers, bags or equipment contaminated with chemicals, pesticides, mineral oil or scheduled wastes

SW 410 Rags, plastics, papers or filters contaminated with scheduled wastes

SW 411 Spent activated carbon excluding carbon from the treatment of potable water and processes of the food industry and vitamin production

SW 416 Sludges of inks, paints, pigments, lacquer, dye or varnish

SW 417 Waste of inks, paints, pigments, lacquer, dye or varnish

SW 418 Discarded or off-specification inks, paints, pigments, lacquer, dye or varnish products containing organic solvent

SW Label recommended for;
SW 324 Waste of halogenated or unhalogenated non-aqueous distillation residues arising from organic solvents recovery process
SW 326 Waste of organic phosphorus compound

SW Label recommended for;
SW 102 Waste of lead acid batteries in whole or crushed form

SW 103 Waste of batteries containing cadmium and nickel or mercury or lithium

SW 104 Dust, slag, dross or ash containing arsenic, mercury, lead, cadmium, chromium, nickel, copper, vanadium, beryllium, antimony, tellurium, thallium or selenium excluding slag from iron and steel factory

SW 105 Galvanic sludges

SW 106 Residues from recovery of acid pickling liquor (if solidified)

SW 110 Waste from electrical and electronic assemblies containing components such as accumulators, mercury-switches, glass from cathode-ray tubes and other activated glass or polychlorinated biphenyl-capacitors, or contaminated with cadmium, mercury, lead, nickel, chromium, copper, lithium, silver, manganese or polychlorinated biphenyl

SW 201 Asbestos wastes in sludges, dust or fibre forms

SW 203 Immobilized scheduled wastes including chemically fixed, encapsulated, solidified or stabilized sludges

SW 205 Waste gypsum arising from chemical industry or power plant

SW 304 Press cake from pretreatment of glycerol soap lye

SW 321 Rubber or latex wastes or sludge containing organic solvents or heavy metals

SW 406 Clinker, slag and ashes from scheduled wastes incinerator

SW 411 Spent activated carbon excluding carbon from the treatment of potable water and processes of the food industry and vitamin production

SW 412 Sludges containing cyanide

SW Label recommended for;
SW 423 Spent processing solution, discarded photographic chemicals or discarded photographic wastes

SW 424 Spent oxidizing agent

SW 425 Wastes from the production, formulation, trade or use of pesticides, herbicides or biocides

SW 426 Off-specification products from the production, formulation, trade or use of pesticides, herbicides or biocides

SW 431 Waste from manufacturing or processing or use of explosives

SW 432 Waste containing, consisting of or contaminated with, peroxides

SW Label recommended for;
SW 101 Waste containing arsenic or its compound

SW 102 Waste of lead acid batteries in whole or crushed form

SW 103 Waste of batteries containing cadmium and nickel or mercury or lithium

SW 105 Galvanic sludges

SW 107 Slags from copper processing for further processing or refining containing arsenic, lead or cadmium

SW 109 Waste containing mercury or its compound

SW 201 Asbestos wastes in sludges, dust or fibre forms

SW 203 Immobilized scheduled wastes including chemically fixed, encapsulated, solidified or stabilized sludges

SW 204 Sludges containing one or several metals including chromium, copper, nickel, zinc, lead, cadmium, aluminium, tin, vanadium and beryllium

SW 302 Flux waste containing mixture of organic acids, solvents or compounds of ammonium chloride

SW 317 Spent organometallic compounds including tetraethyl lead, tetramethyl lead and organotin compounds

SW 318 Waste, substances and articles containing or contaminated with polychlorinated biphenyls (PCB) or polychlorinated triphenyls (PCT)

SW 319 Waste of phenols or phenol compounds including chlorophenol in the form of liquids or sludges

SW 320 Waste containing formaldehyde

SW 321 Rubber or latex wastes or sludge containing organic solvents or heavy metals

SW 327 Waste of thermal fluids (heat transfer) such as ethylene glycol

SW 407 Waste containing dioxins or furans

SW 408 Contaminated soil, debris or matter resulting from cleaning-up of a spill of chemical, mineral oil or scheduled wastes

SW 412 Sludges containing cyanide

SW 413 Spent salt containing cyanide

SW 414 Spent aqueous alkaline solution containing cyanide

SW 415 Spent quenching oils containing cyanides

SW 419 Spent di-isocyanates and residues of isocyanate compounds excluding solid polymeric material from foam manufacturing process

SW 420 Leachate from scheduled waste landfill

SW 421 A mixture of scheduled wastes

SW 422 A mixture of scheduled and non-scheduled wastes

SW 423 Spent processing solution, discarded photographic chemicals or discarded photographic wastes

SW 424 Spent oxidizing agent

SW 425 Wastes from the production, formulation, trade or use of pesticides, herbicides or biocides

SW 426 Off-specification products from the production, formulation, trade or use of pesticides, herbicides or biocides

SW 427 Mineral sludges including calcium hydroxide sludges, phosphating sludges, calcium sulphite sludges and carbonates sludges

SW 428 Wastes from wood preserving operation using inorganic salts containing copper, chromium or arsenic of fluoride compounds or using compound containing chlorinated phenol or creosote

SW 429 Chemicals that are discarded or off-specification

SW 430 Obsolete laboratory chemicals

SW 431 Waste from manufacturing or processing or use of explosives

SW 432 Waste containing, consisting of or contaminated with, peroxides

SW Label recommended for;
SW 403 Discarded drugs containing psychotropic substances or containing substances that are toxic, harmful, carcinogenic, mutagenic or teratogenic

SW 404 Pathogenic wastes, clinical wastes or quarantined materials

SW 405 Waste arising from the preparation and production of pharmaceutical product

SW Label recommended for;
SW 106 Residues from recovery of acid pickling liquor

SW 206 Spent inorganic acids

SW 207 Sludges containing fluoride

SW 301 Spent organic acids with pH less or equal to 2 which are corrosive or hazardous

SW 302 Flux waste containing mixture of organic acids, solvents or compounds of ammonium chloride

SW 327 Waste of thermal fluids (heat transfer) such as ethylene glycol

SW 401 Spent alkalis containing heavy metals

SW 402 Spent alkalis with pH more or equal to 11.5 which are corrosive or hazardous

SW Label recommended for;
SW 106 Residues from recovery of acid pickling liquor

SW 107 Slags from copper processing for further processing or refining containing arsenic, lead or cadmium

SW 108 Leaching residues from zinc processing in dust and sludges form

SW 109 Waste containing mercury or its compound

SW 202 Waste catalysts

SW 203 Immobilized scheduled wastes including chemically fixed, encapsulated, solidified or stabilized sludges

SW 204 Sludges containing one or several metals including chromium, copper, nickel, zinc, lead, cadmium, aluminium, tin, vanadium and beryllium

SW 303 Adhesive or glue waste containing organic solvents excluding solid polymeric materials

SW 401 Spent alkalis containing heavy metals

SW 406 Clinker, slag and ashes from scheduled wastes incinerator

SW 408 Contaminated soil, debris or matter resulting from cleaning-up of a spill of chemical, mineral oil or scheduled wastes

SW 409 Disposed containers, bags or equipment contaminated with chemicals, pesticides, mineral oil or scheduled wastes

SW 410 Rags, plastics, papers or filters contaminated with scheduled wastes

SW 420 Leachate from scheduled waste landfill

SW 421 A mixture of scheduled wastes

SW 422 A mixture of scheduled and non-scheduled wastes

SW 427 Mineral sludges including calcium hydroxide sludges, phosphating sludges, calcium sulphite sludges and carbonates sludges

SW 428 Wastes from wood preserving operation using inorganic salts containing copper, chromium or arsenic of fluoride compounds or using compound containing chlorinated phenol or creosote

SW 429 Chemicals that are discarded or off-specification

SW 501 Any residues from treatment or recovery of scheduled wastes

Waste generator shall keep an inventory of scheduled wastes

Regulation 11.

A waste generator shall keep accurate and up‑to‑date inventory in accordance with the Fifth Schedule of the categories and quantities of scheduled wastes being generated, treated and disposed of and of materials or product recovered from such scheduled wastes for a period up to three years from the date the scheduled

Discussion: The DOE, as in practice at this point of writing, do encourage the submission of the inventory record via email or on-line transmission. This may not be clearly written in the law but the agency has legal means for such request.

Information to be provided by waste generator, contractor and occupier of prescribed premises

Regulation 12.

(1) A waste generator, contractor and occupier of the prescribed premises shall provide information in accordance with the Sixth Schedule in the manner provided in this regulation or Director General shall determine other method as he thinks fit.

(2) A waste generator shall complete Part I of the Sixth Schedule in six copies and hand over the six copies of the Schedule to the contractor when the scheduled wastes are delivered to him.

(3) The contractor shall, upon receiving scheduled wastes from a waste generator, complete Part II of the Sixth Schedule in the six copies given to him by the waste generator and shall thereafter immediately hand over two copies of the Schedule to the waste generator who in turn shall submit a copy to the Director General within 30 days from the date of transportation of the scheduled wastes.

(4) The contractor shall, within 10 days from the date of receipt of the scheduled wastes, deliver the scheduled wastes to the occupier of any prescribed premises and hand over the remaining four copies of the Sixth Schedule to the occupier.

(5) The occupier of any prescribed premises shall, upon receiving scheduled wastes from the contractor, complete Part III of all the remaining four copies of the Sixth Schedule handed over to him by the contractor and shall, upon completion, retain one copy and return a copy each to the contractor, the waste generator and the Director General, within 20 days from the date of receipt of the scheduled wastes.

(6) If the waste generator fails to receive his copy of the Sixth Schedule from the occupier of the prescribed premises referred to in subregulation (5) within 30 days from the date of delivery of the scheduled wastes to the contractor referred to in subregulation (2), he shall notify the Director General immediately and shall investigate and inform the Director General of the result of his investigation.

(7) The waste generator, contractor or occupier of the prescribed premises shall keep a copy each of the Sixth Schedule. The Sign copy of Sixth Schedule must be retained as a record for at least three years from the date the scheduled wastes are accepted by the prescribed premises.

Discussion: The DOE, as in practice at this point of writing, do encourage the submission of the consignment no via email or on-line transmission. This may not be clearly written in the law but the agency has legal means for such request.

Scheduled wastes transported outside waste generator’s premises to be accompanied by information

Regulation 13.

(1) Every waste generator shall provide information in accordance with the Seventh Schedule in respect of each category of scheduled wastes to be delivered to the contractor and shall give the Schedule to the contractor upon delivery of the waste to him. (2) The waste generator shall inform the contractor of the purpose and use of the Seventh Schedule.

(3) The contractor shall carry with him the Seventh Schedule for each category of scheduled wastes being transported and shall observe and comply with the instructions contained therein.

(4) The contractor shall, in the selection of transportation routes, as far as possible avoid densely populated areas, water catchment areas and other environmentally sensitive areas.

(5) The contractor shall ensure that all his employees that are involved in the handling, transportation and storage of scheduled wastes attend training programmes.

(6) The contractor shall ensure that during the training programme each employee is well informed on the purpose and use of the Seventh Schedule.

Discussion: The Seventh Schedule is popularly referred by the DOE as 'Waste Card'. Personally I'd call it WSDS (Waste Safety Data Sheet) - sounds handy right!
Internal Auditors: Please perform some 'ad-hoc' spot-checks to ensure that your SW Contractors do have the respective and relevant Waste Cards in their vehicle in every transaction.
Waste Generators' Signatories: Please check for the same prior undersigning the e-consignment note and before the SW contractors leaves your premise.
Remember: A SW Generator is responsible for their SW from Cradle to Cradle - so preached by the DOE.

Spill or accidental discharge

Regulation 14.

(1) In the event of any spill or accidental discharge of any scheduled wastes, the contractor responsible for the waste shall immediately inform the Director General of the occurrence.

(2) The contractor shall do everything that is practicable to contain, cleanse or abate the spill or accidental discharge and to recover substances involved in the spill or accidental discharge.

(3) The waste generator shall provide technical expertise and supporting assistance in any clean‑up operation referred to in subregulation (2).

(4) The contractor shall undertake studies to determine the impact of the spillage or accidental discharge on the environment over a period of time to be determined by the Director General.
Discussion: Who is responsible to do What? When? How?
Internal Auditors: Please ensure that your SW Contractors do have the respective and relevant ERP procedures, ERP basic equipments and tools, Waste Cards and PPE in their vehicle in every transaction.
Waste Generators: Please observe very carefully the term 'technical expertise' as in sub-clause (3) above.
Remember: A SW Generator is responsible for their SW from Cradle to Cradle - so preached by the DOE.
Training Programme

Regulation 15.

Every waste generator shall ensure that all his employees involved in the identification, handling, labeling, transportation, storage and spill response of scheduled wastes, attend training programme.

Compounding of offences

Regulation 16.

(1) Every offence which consists of any omission or neglect to comply with, or any act done or attempted to be done contrary to these Regulations may be compounded under section 45 of the Act.

(2) The compounding of offences referred to in subregulation (1) shall be in accordance with the procedure prescribed in the Environmental Quality (Compounding of Offences) Rules 1978 [P.U. (A) 281/1978].

GUIDELINES FOR THE APPLICATION OF SPECIAL MANAGEMENT OF SCHEDULED WASTE

The Malaysian Department of Environment (DOE) has classified certain wastes and defined them as scheduled wastes as listed in the First Schedule of the Environmental Quality (Scheduled Wastes) Regulations, 2005. In some cases, however, some of these scheduled wastes does not exhibit any hazardous characteristic and does not pose any potential hazard either to human health or to the environment. Therefore, this legislation provides a provision for the application for the special management of schedule waste, for declassification. One’s waste may be raw materials for others.

APPLICATION FOR SPECIAL MANAGEMENT OF SCHEDULED WASTE

1. Under Regulations 7 of the Environmental Quality (Scheduled Wastes) Regulations, 2005, a generator of scheduled wastes may apply to the Director General of Environmental Quality to exclude a specific scheduled waste from scheduled waste regulations.

2. The general requirements for the application are described in this guideline.

3. Any scheduled waste generator may manage it’s waste as non scheduled wastes after the Director General of Environmental Quality grants a written approval or exclusion.

APPLICATION FOR INFORMATION REQUIREMENTS

4. In order for the waste to be excluded from the requirements scheduled waste regulations requirement, scheduled waste generators must demonstrate that the waste :-

i) Does not exhibit any of the hazardous wastes characteristic - ignitability, reactivity, corrosivity and toxicity , as defined in Appendix 1;

ii) Has been proven by scientific studies and tests on its toxicity and carcinogenic and does not have hazard effects on human or other life forms as specified in Appendix 2, which amounted to concentration which is equal to, or exceeds the percentage limits (percentage weights) specified in Appendix 3 . A generator/ applicant shall submit reports, records or journals in order to prove that the waste does not exhibit any of the elements mentioned; and

iii) It is not capable of posing potential hazard to human health or the environment when improperly treated, stored, transported or disposed of, or otherwise managed.

7. The applicant shall provide the information as required in AS WM 1/4 form together with processing fee of RM 300.00 which is not refundable (Appendix 4).

Appendix 1

CHARACTERISTIC OF HAZARDOUS WASTE

It is the responsibility of waste generator to determine whether his waste exhibits one or more of these characteristics.

The following are the scheduled wastes and thus subject to determination as whether they exhibit hazardous and/or toxic characteristics:

- Air pollution control residues, including dusts, ashes, carbon and other reagents and sludges.

- Dust, powder, ash, slag and dross from metals processing, including smelting and soldering.

- Contaminated soil and water deriving from construction activities, such as excavation, dredging

Characteristic of corrosivity.

A waste exhibits the characteristic of corrosivity if a representative sample of the waste has either of the following properties:

(1) It has an aqueous component and has a pH less than or equal to 2, or greater than or equal to 12.5, as determined by a pH meter.

(2) It has a liquid component and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55^oC (130^oF).

Characteristic of ignitability.

A waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties:

(1) It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has flash point less than 60^oC (140^oF), as determined by a Pensky-Martens Closed Cup Tester or a Setaflash Closed Cup Tester.

(2) It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates hazard.

(3) It is an ignitable compressed gas.

(4) It is an oxidizer.

Characteristic of reactivity.

A waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:

(1) It is normally unstable and readily undergoes violent changes without detonating.

(2) It reacts violently with water.

(3) It forms potentially explosive mixtures with water.

(4) When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

(5) It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.

(6) It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

(7) It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

(8) It is a forbidden explosive.

Toxicity characteristic.

A waste exhibits the characteristic of toxicity if, the extract from a representative sample of the waste contains any of the contaminants listed in Table 1 at the concentration equal to or greater than the respective value given in that table.

Table 1. -- Maximum Concentration of Contaminants for the Toxicity Characteristic (TCLP);
DOE CW No. ¹	Contaminant	CAS No. ²	Regulatory Level (mg/L)
C004	Arsenic	7440-38-2	5.0
C005	Barium	7440-39-3	100.0
C018	Benzene	71-43-2	0.5
C006	Cadmium	7440-43-9	1.0
C019	Carbon tetrachloride	56-23-5	0.5
C020	Chlordane	57-74-9	0.03
C021	Chlorobenzene	108-90-7	100.0
C022	Chloroform	67-66-3	6.0
C007	Chromium	7440-47-3	5.0
C023	o-Cresol	95-48-7	⁴ 200.0
C024	m-Cresol	108-39-4	⁴ 200.0
C025	p-Cresol	106-44-5	⁴ 200.0
C026	Cresol		⁴ 200.0
C016	2,4-D	94-75-7	10.0
C027	1,4-Dichlorobenzene	106-46-7	7.5
C028	1,2-Dichloroethane	107-06-2	0.5
C029	1,1-Dichloroethylene	75-35-4	0.7
C030	2,4-Dinitrotoluene	121-14-2	³ 0.13
C012	Endrin	72-20-8	0.02
C031	Heptachlor (and its epoxide)	76-44-8	0.008
C032	Hexachlorobenzene	118-74-1	³ 0.13
C033	Hexachlorobutadiene	87-68-3	0.5
C034	Hexachloroethane	67-72-1	3.0
C008	Lead	7439-92-1	5.0
C013	Lindane	58-89-9	0.4
C009	Mercury	7439-97-6	0.2
C014	Methoxychlor	72-43-5	10.0
C035	Methyl ethyl ketone	78-93-3	200.0
C036	Nitrobenzene	98-95-3	2.0
C037	Pentrachlorophenol	87-86-5	100.0
C038	Pyridine	110-86-1	³ 5.0
C010	Selenium	7782-49-2	1.0
C011	Silver	7440-22-4	5.0
C039	Tetrachloroethylene	127-18-4	0.7
C015	Toxaphene	8001-35-2	0.5
C040	Trichloroethylene	79-01-6	0.5
C041	2,4,5-Trichlorophenol	95-95-4	400.0
C042	2,4,6-Trichlorophenol	88-06-2	2.0
C017	2,4,5-TP (Silvex)	93-72-1	1.0
C043	Vinyl chloride	75-01-4	0.2

FOOTNOTE: Characteristic waste number.

FOOTNOTE: ²Chemical abstracts service number.

FOOTNOTE: ³Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level.

FOOTNOTE: ⁴If o-, m-, and p-Cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used. The regulatory level of total cresol is 200 mg/l.

Table 2 : Compositional Analysis (Dry Basis)

California Assessment Code Title 26 STLC (Soluble Threshold Limit Concentration) and TTLC (Total Threshold Limit Concentration.

TTLC STLC

mg/kg mg/L

Metals

Antimony (Sb) 500 15

Arsenic (As) 500 5

Barium (Ba) 10000 100

Berylium (Be) 75 0.75

Cadmium (Cd) 100 1

Chromium (Cr) 2500 560

Chromium-VI (CrVI) 500 5

Cobalt (Co) 8000 80

Copper (Cu) 2500 25

Lead (Pb) 1000 5

Mercury (Hg) 20 0.2

Molybdenum (Mo) 3500 350

Nickel (Ni) 2000 20

Selenium (Se) 100 1

Silver (Ag) 500 5

Thallium (TI) 700 7

Vanadium (V) 2400 24

Zinc (Zn) 5000 250

Semivolatile Organics

o-Cresol

m-Cresol

p-Cresol

Cresol, Total

1.4-Dichlorobenzene

2.4-Dinitrotoluene

Hexachlorobenzene

Hexachlorobutadience

Hexachloroethane

Nitrobenzene

Pentachlorophenol 17 1.7

2,4,5-Trichlorophenol

2,4,6- Trichlorophenol

Herbicides

2,4-Dichlorophenoxy acetic acid 100 10

2,4,5-Trichlorophenoxypropionic acid (Silvex) 10 1

Volatile Organics

Benzene

Carbon Tetrachloride

Chlorobenzene

Chloroform

1,2-Dichoroethane

1,1-Dicholoethylene

Methyl Ethyl Ketone

Pyridine

Trichloroethylene 2040 204

Tetrachlroethylene

Vinyl Chloride

Pesticides and PCBs

Aldrin 1.4 0.14

Chlordane 2.5 0.25

DDT, DDE, DDD 1 0.1

Dieldrin 8 0.8

Endrin 0.2 0.02

Heptachlor 4.7 0.47

Kepone 21 2.1

Lindane 4 0.4

Methoxychlor 100 10

Mirex 21 2.1

PCBs 50 5

Toxaphene 5 0.5

Miscellaneous

Asbestos 1%

Dioxin (2,3,7,8-TCDD) 0.01 0.001

Fluoride salts 18000 180

Organic Lead 13

1. If o-,m-, and p-Cresol concentrations cannot be differentiated, the total Cresol concentration is used.

2. Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level.

Appendix 2

PROPERTIES OF WASTES WHICH RENDER THEM HAZARDOUS

Waste is regarded as hazardous if it demonstrates one or more of the following properties. If the waste contains a mixture with one or more chemical substances which demonstrate these properties, evaluation shall take into account the total content of these substances, as specified in Appendix 2.

Fire hazard	1. Explosive : solid, liquid, paste-like, or gelatinous substances or products which, without the effect of flame, can react to produce violent generation of heat with rapid generation of gas, and which under specific test conditions detonate and rapidly deflagrate, or when heated inpart confinement, explode.
	2. Oxidising : Substances and products which exhibit highly exothermic reactions when in contact with other substances, particularly flammable substances.
	3. Flammable : Substances and products (including those which are extremely flammable and highly flammable) which: ¨ Become hot and finally catch fire in contact with air at ambient temperature without any application of energy; or ¨ In solid form may readily catch fire after brief contact with a source of ignition and which continue to burn or be consumed after the removal of the source of ignition; or ¨ In liquid form have a flash point of lower than 0^oC and a boiling point lower than or equals to 35^oC (extremely flammable) ; a flash point below 21^oC (highly flammable); a flash point equals to or greater than 21^oC and less than or equals to 55^oC (flammable). ¨ In contact with water or damp air evolve highly flammable gases in dangerous quantities, or ¨ Liquid substances and products with a low flash point
Health hazard	4. Very toxic: Substances and products which : ¨ If they are inhaled or ingested, or if they penetrate may involve extremely serious, acute or chronic health risks or even death; or ¨ The LD50 absorbed orally in rat is less than 25 mg/kg or the LD-50 percutaneous absorption in rat or rabbit is less than 50 mg/kg or the LC-50 absorbed by inhalation in rat is less than 0.5 mg/liter (administered for a minimum period of four hours)
	5. Toxic: Substances and products which : ¨ If they are inhaled or ingested, or if they penetrate the skin may involve serious, acute or chronic health risks or even death; or ¨ The LD50 absorbed orally in rat is between 25 to 200 mg/kg or the LD-50 percutaneous absorption in rat or rabbit is between 50 to 400 mg/kg or the LC-50 absorbed by inhalation in rat is between 0.5 to 2 mg/liter (administered for a minimum period of four hours)
	6. Harmful : Substances and products which: ¨ if they are inhaled or ingested, or if they penetrate the skin may involve limited health risks; or ¨ The LD50 absorbed orally in rat is between 200 to 500 mg/kg or the LD-50 percutaneous absorption in rat or rabbit is between 400 to 2000 mg/kg or the LC-50 absorbed by inhalation in rat is between 2 to 20 mg/liter (administered for a minimum period of four hours)
	7. Corrosive: Substances or products which may destroy living tissue on contact.
	8. Irritant : Substances or products which, without being corrosive, may cause inflammation through immediate, prolonged or repeated contact with the skin or mucous membrane.
	9. Carcinogenic: Substances and products which if they are inhaled or ingested, or if they penetrate the skin, may induce cancer or increases its incidence.
	10. Mutagenic : Substances and products which if they are inhaled or ingested, or if they penetrate the skin, may induce hereditary genetic defects or increase their incidence.
	11. Teratogenic and harmful to fertility: Substances and products which if they are inhaled or ingested, or if they penetrate the skin, may induce or increase the incidence of non-hereditary side-effects in offspring or a deterioration of male or female fertility or ability to fertilise.
Harmful to the environment	12. Ecotoxic: Substances and products which present, or may present immediate or delayed risks for one or more sectors of the environment.
Infectious	13. Infectious: Substances containing viable micro-organisms or their toxins which are known or reliably believed to cause disease in man or other living organisms.

Methods of examination

In testing for characteristics 1 to 11, the method of examination used shall be as stated in the following European Community (EC) Directives:

i. Council Directive 87/302/European Economic Commission (EEC)¹ for toxicity and ecotoxicity tests;

ii. Council Directive 92/69/EEC² for physical, chemical, toxicity and ecotoxiciy tests; and

iii. Council Directive 96/54/EC³ for toxicity and health effects tests.

_______________________________

¹Official Journal (OJ) No. L133 30/5/1998

²OJ No. L383 29/12/1992

³OJ No. L248 30/9/1996

Appendix 3

Percentage limitations which render waste non hazardous

In the assessment of whether waste which contains a mixture of one or more chemical substances is hazardous, characteristics which are mentioned in Appendix 1 should be taken into account.

Waste is hazardous under all circumstances if:

¨ The flash point of the waste is less than or equals to 55^oC and/or if:

¨ The sum of the composite, chemical substance(s) which exhibit the characteristics specified in the Appendix 1 amounts to a concentration which is equal to, or exceeds, the following percentage limits (percentage weights).

Characteristic	%
Highly toxic (R26, R27, R28, R39)¹)	0.1
Toxic (R23, R24, R25)¹)	3
Toxic (R48, R39)¹)	1
Health hazard (R20, R21, R22)¹)	25
Health hazard (R48)¹)	10
Corrosive (R35)¹)	1
Corrosive (R34)¹)	5
Irritant (R36, R37, R38)¹)	20
Irritant (R41)¹)	5
Carcinogenic, category 1 or 2 (R45, R49)¹)	0.1²)
Carcinogenic, category 3 (R40)¹)	1²)
Mutagenic, category 1 or 2 (R46)¹)	0.1²)
Mutagenic, category 3 (R40)¹)	1²)
Teratogenic and harmful to fertility, category 1 or 2 (R60, R61)¹)	0.5²)
Teratogenic and harmful to fertility, category 3 (R62, R63)¹)	5²)
Ecotoxic, marine environment (R50, R51, R52, R53) and other ecosystems (R54, R55, R56, R57, R58, R59)¹)	Not set
Infectious	Not set

______________________________________________________________________

¹) Refer to the Department of Safety and Health’s prevailing regulations on classification, packaging and labeling of hazardous chemicals, namely the Occupational Safety And Health (Classification, Packaging And Labeling Of Hazardous Chemicals) Regulations 1997 or EC Council Directive 91/689/EEC.

²) Concentration limits apply to individual chemical substances with the relevant characteristics.

Appendix 4

(AS. WM-1/04)

APPLICATION FOR SPECIAL MANAGEMENT OF SCHEDULED WASTE UNDER REGULATION 7, ENVIRONMENTAL QUALITY (SCHEDULED WASTES) REGULATIONS 2004

A. PENGENALAN

IDENTIFICATION

1. (i) Nama Pemohon:

Name of Applicant

(ii) Alamat Pemohon:

Address of Applicant

(iii) Telefon:

Telephone

(iv) Telefaks:

Telefax

2. (i) Nama Premis:

Name of Premises

(ii) Alamat Premis:

Address of Premises

(iii) Telefon:

Telephone

(iv) Telefaks:

Telefax

B. MAKLUMAT OPERASI

OPERATIONAL INFORMATION

3. Justifikasi bagi permohonan

Justification for application

4. Lampirkan senarai bahan-bahan mentah utama dan kuantiti yang digunakan

Attach list of main raw materials and the quantity used

5. Lampirkan senarai hasil pengeluaran

Attach list of final products

6. Lampirkan keterangan proses pengeluaran dan rajah aliran yang berkaitan

Attach description of production processes and the relevant flow diagrams

C. PENGURUSAN BUANGAN TERJADUAL

SCHEDULED WASTE MANAGEMENT

7. Keterangan mengenai buangan terjadual yang dipohon untuk pengurusan khas cth. kategori dan kuantiti buangan terjadual

Description of the specific schedule waste applied for the exclusion ie. scheduled waste category and quantity.

8. Senarai asas buangan terjadual – keterangan mengapa buangan dikategorikan sebagai buangan terjadual.

Basis Scheduled waste listing – describe on why the waste is classified as scheduled waste

9. Sejarah penghasilan buangan terjadual – samaada ia telah dihasilkan, sedang dihasilkan atau akan dihasilkan dimasa hadapan.

History of scheduled waste generation-whether it has been generated in the past, is presently generated or will be generated in the future.

10. Jumlah buangan – purata dan jumlah maksimum buangan yang dihasilkan mengikut bulan atau tahun.

Waste volume-average and maximum volume of waste generated monthly or annually.

11. Sejarah pelupusan buangan terjadual – kaedah pelupusan dahulu, sekarang dan dimasa akan datang.

Schedule waste disposal history- disposal method on the past, present and future.

12. Bagaimana buangan terjadual akan diuruskan jika permohonan dibenarkan.

How the scheduled waste will be managed if application is granted

D MAKLUMAT PROSES DAN PENGURUSAN BUANGAN TERJADUAL

PROCESS AND SCHEDULED WASTE MANAGEMENT INFORMATION

13. Maklumat mengenai semua proses dan bahan mentah yang digunakan yang menyumbang kepada buangan terjadual

Information on everyl processes and raw materials contributing to the scheduled wastes.

14. Penjelasan samaada buangan terjadual dihasilkan daripada proses perkilangan atau proses loji pengolahan air buangan, pemprosesan bahan, operasi pengurusan buangan dan lain-lain operasi yang boleh menyumbang kepada terhasilnya buangan terjadual.

Clarify whether the scheduled waste is generated from manufacturing process or wastewater treatment process, process materials, waste management operations and other facility operations that might contribute to the scheduled waste.

E. PENYENARAIAN SEMUA BAHAN BERBAHAYA

LIST OF ALL HAZARDOUS CONSTITUENTS

15. Penyenaraian bahan-bahan difikirkan perlu diberi perhatian dan semua ciri-ciri buangan merbahaya hendaklah dikemukakan dalam semua pemohonan

Develop a list of constituents of concern and hazardous waste characteristic in generaland this should be addressed in all applications.

16. Menjalankan analisis bagi mengenalpasti lain-lain bahan kimia yang merbahaya mungkin wujud dalam buangan

Conduct an analysis to identify whether any other constituents of concern may be present in the waste.

17. Mengenalpasti mana-mana bahan yang mana kajian akan dijalankan berdasarkan kepada senarai

Identify constituents for which testing study would be conducted, based on the list.

18. Mengenalpasti kawalan kualiti bagi tujuan kajian buangan

Identify quality control for waste study.

F. MAKLUMAT PERSAMPELAN BUANGAN

WASTE SAMPLING INFORMATION

20. Teknik pengendalian & penyediaan yang digunakan bagi setiap sampel dan jenis dan jumlah pengawet yang digunakan.

Handling & preparation techniques used for each sample and types and amounts of preservatives used.

G. MAKLUMAT ANALISIS BUANGAN

WASTE ANALYSIS INFORMATION

21. Samaada pengambilan sampel mewakili buangan terjadual yang berubah atau seragam

Whether collected samples represent the variability or uniformity of the scheduled waste.

22. Persampelan dijalankan oleh orang yang berkelayakan

Waste sampling was conducted by qualified personnel.

D. BAYARAN

FEE

23. Bayaran memproses: RM300.00

Processing Fee

24. Disertakan Kiriman Wang/Wang Pos/Bank Draf bernombor :

Enclosed Money Order/Postal Order/Bank Draft number :_________________

berjumlah RM 300.00 untuk bayaran memproses kebenaran bertulis.

of RM 300.00 for the written permission processing fee.

Saya, dengan ini mengaku bahawa segala maklumat yang diberi dalam permohonan ini adalah

benar dan betul sepanjang pengetahuan dan kepercayaan saya.

I, hereby declare that all information given in this application is to the best of my knowledge and belief true and correct

Tandatangan:

Signature:

Nama:

Name:

Jawatan:

Designation:

Pengesahan:

Certified Stamp:

Tarikh:

Date:

Points to ponder

How the ISO14001's 'Input-Output' Analysis is helpful in identifying Environmental Aspects which are Scheduled Wastes?

The electroplating process generates an array of Scheduled Wastes.
Identification of environmental aspects which are Scheduled Waste
requires such comprehensive approach. Legal obligation and liability.

It is for this very reason that one should not simplify this method further. I worry about perhaps some potential misinterpretation by those who don't have enough time to think what they read, of what is written in Guidance Clause A.6.1.2, paragraph 5 of the ISO14001:2015 which states .. " An organization does not have to consider each product, component or raw material individually to determine and evaluate their environmental aspects; it may group or categorize activities, products and services when they have common characteristics." Regrouping some manufacturing activities or processes scheme into one category say 'Production' is indeed a good summary but may lead to the omission or 'overlooking' of important environmental aspects. This paragraph may be disconcerting to the prime objective of an EMS, unless, it's just merely for certification.

Khalid Mohd Ariff
Email: sekitar521@gmail.com

Sekitar Synergy Sdn Bhd

Pages

SW List & Law

Methods of examination

Characteristic

4 comments: