The EU-Commission has submitted a request for opinions with questions regarding directive 91/689/EEC on hazardous waste. The Bellona Foundation acknowledges the strong connection between waste and hazardous waste and recommends the integration of the directive into the Waste Framework Directive, which is due for revision.

The boundaries between what substances are to be considered harmful to human health and the environment are constantly changing. Examples of this are the use of brominated flame-retardants and PCB. The Bellona Foundation supports the idea of integrating hazardous substances in the environmentally appropriate treatment of the different waste fractions.

This might be especially important for historical waste originating from products with a long life span. Historical waste can be defined as waste with origin in products with a long life span, for instance buildings that have a life span of 50 to 100 years. The problem considering boundaries between different types of waste is especially probelmatic considering the large amount of historical waste that was considered harmless to health and the environment at the time the product was made—and which must be treated as hazardous waste in the years to come.

Bellona also addresses in its position paper mixing of different wastes as a problem. Mixing of hazardous waste with other kinds of waste could be used as a strategy for dilution. This lowers the concentration of harmful substances in emissions to soil, water and air, and makes it difficult to track down actors that profit from irresponsible hazardous waste handling and treatment policies The Bellona Foundation recommends the development of specific guidelines for what treatment is acceptable for the different waste categories, and that emission allowances are developed with regard on the guidelines for what is current the best available technique (BAT) for waste treatment within that category, according to the IPPC directive.

Read Bellona’s response to the consultation here