Document(s) 11 of 15

Introduction

All economic activity is derived from a set of environmental resources and services.¹ Simultaneously, however, the current functioning of economic systems depletes and degrades these resources and services in a variety of ways. Modern industrial economies are pulling the environmental rug from under their own feet. The degradation of environmental support systems occurs by two routes: a depletion of resources necessary for the continued viability of the biosphere (such as water resources) and pollution of the biosphere such that its functioning and its continued ability to assimilate waste materials from economic processes (such as ozone-layer destruction) are impaired.

The primary unsustainable activity of economies was previously thought to be the depletion of non-renewable natural resources—the running down of stocks of minerals and metals to construct, and fuels to power, the economy. However, it has become clear that pollution caused in the extraction and use of these resources is going to constrain their current methods of use well before they are in danger of depletion (Jacobs 1992). Waste products from industrial societies are entering the environment at a rate far greater than the rate of natural absorption and breakdown of these substances. Furthermore, much of the waste from industrial processes is in the form of substances which are either toxic or extremely resistant to natural degradation.

The environmental effects of pollution are myriad and occur at all levels—from the key global problems of ozone depletion and global warming, to local and regional problems of acid precipitation from sulphur and nitrogen oxide emissions. Pollution also directly endangers human health. According to Jacobs (1992), a study by the United States Environmental Protection Agency of toxic air emissions in the USA has directly linked 2 000 cancer deaths each year to a mere third of these emissions. The World Commission on Environment and Development concluded that “the sources and causes of pollution are far more diffuse, complex and interrelated—and the effects of pollution more widespread, cumulative and chronic—than hitherto believed” (1987: 211).

¹I would like to thank Iain McGlinchy of the Ministry of the Environment, New Zealand, and Achim Halpap, of the United Nations Institute for Training and Research, for their help in providing me with access to information on pollution release registers from around the world.

South Africa is not immune to these problems and, in fact, is less prepared than most industrialised countries to control industrial pollution. This chapter evaluates South Africa’s hazardous waste production and management situation. It considers the need for an integrated pollution control system in South Africa and the central role that reliable information will play in the effective operation of such a system. In particular the paper evaluates the use of pollution release inventories, how they have been used in other countries, how an inventory would relate to current pollution control processes and what the needs of a process of implementation are.

Pollution control: A new industrial sector

Internationally, governments and industries have rapidly responded to the growing problems of pollution control through legislation, new technology, changed industrial processes and large expenditures on pollution control equipment. The control of pollution to air, water and land media constitutes the largest area of environment protective expenditure in developed countries. During the last decade public and private expenditure on pollution abatement in Organisation for Economic Cooperation and Development (OECD) countries ranged from 1-2% of GDP, with expectations of steep rises. By the year 2000 the USA expects to raise its pollution abatement expenditure from $115 billion to $171 billion in real terms, equivalent to about 2,8% of GDP (Doeleman 1992).

Certain industrial sectors have expenditures far higher than the national averages for pollution control. It is estimated that between 10-20% of Western Europe’s chemical industry capital expenditure in 1989 was channelled towards environmental spending. This was of a total of about $25 billion and was expected to rise to about 25% of total capital expenditure in the 1990s. Most of this was from waste elimination (International Labour Organisation 1994).

There are no comparative figures for South Africa, but in all likelihood expenditure in South Africa makes up a lesser, but growing, percentage of GDP than in the OECD nations. As the World Commission on Environment and Development report pointed out, “pollution control of industry has become a thriving branch of industry in its own right in several industrialised countries. …looking to the future, a growing market for pollution control systems, equipment and services is expected in practically all industrialised countries, including newly industrialised countries” (World Commission on Environment and Development 1987).

It is evident that pollution control is internationally becoming a significant industrial sector and is absorbing a significant percentage of industrial investment and expenditure. Pollution control is a growth area driven largely by legislation, public pressure and corporate risk aversion. However, for a sector so dependent on public policy there is surprisingly little information publicly available in South Africa. The size, geographical extent, projected growth and other essential data for this aspect of industry are little known.

As Rogerson points out, “environmental scientists in South Africa largely have eschewed research which identifies clearly the geographical sources of pollutants or hazardous industrial waste” (Rogerson 1990). There is scant data on the actual levels of industrial releases of pollutants, of their composition, of projected releases or of acceptable levels of releases. Furthermore, of the existing data only a small part is held by the state or publicly available.

The waste legacy and its costs

The history of solid waste management in South Africa also provides some compelling reasons to review the management and control of pollution. South Africa has a legacy of poor management of solid waste in general and toxic substances in particular, and as yet no significant policy to either remedy past failings or to ensure that releases of hazardous chemicals to the environment are properly monitored, controlled and limited to acceptable levels. According to waste management company Waste-Tech, South Africa is “saddled with a waste management problem of historic proportions” (Waste-Tech, undated).

Even if improved management is instituted in the near future, there are significant costs that will probably have to be borne in order to remedy the poor practices of the past. There are between 1200 (Moon 1995) and 1 600 landfill sites in South Africa (Noble 1995). A survey of 541 of these sites (Department of Environmental Affairs and Tourism 1992) found that only 92, or 17%, were licensed. Furthermore, although most of these were not hazardous waste sites, nor designed as such, many of them had accepted some industrial waste at some stage. Conditions that could lead to contamination of water resources existed at over half of the landfills, and many accepted waste for which they were not designed. The same study found that almost no landfill sites have records of substances accepted which go back more than ten years. Even recent information is scanty, as only the sites run by the larger organisations keep waste-acceptance databases.

The economic, social and environmental implications of this are enormous. It is very difficult to ascertain the clean-up costs associated with the remediation of unsuitable sites contaminated with hazardous wastes. However, some ballpark figures can be provided to show the expenses generated by a inadequate waste management system.

The USA has the longest and most comprehensive experience of environmental cleanup. Following the passage of the Comprehensive Environmental Response, Compensation and Liability Act, commonly known as Superfund, the Environmental Protection Agency was tasked with the enormous job of cleaning up over 2 000 priority contaminated sites (Davis and Hyfantis 1993). The experience gained thus far in this process will prove very useful in providing data on the use of technical, legal and economic instruments in the remediation of toxic waste contamination in South Africa.

Davis and Hyfantis (1993) have estimated the average clean-up costs thus far under Superfund, and have also estimated the costs for less stringent remediation scenarios:

• scenario 1 is the actual documented cost estimates for the remedial programmes currently proposed ($32 million per site);
  
  
• scenario 2 involves merely fencing off sites and monitoring contaminated groundwater to ensure that contamination does not migrate ($2,1 million per site);
  
  
• scenario 3 adds certain technologies which further reduce toxin mobility such as capping, vertical barriers and surface water diversion ($6,6 million per site).

To determine South Africa’s clean-up costs the number of sites requiring remediation needs to be estimated. As indicated, lack of information means that any figure will be associated with a high degree of uncertainty. Nevertheless, going on the available information we can derive some ballpark figures. Using only the information from the sites actually covered by the Department of Environmental Affairs survey—a very conservative estimate—we can see that of the Class I (containment) and Class II (attenuation) sites surveyed, 105 admitted to having control problems. If we use the study’s assumption that over half of these were accepting hazardous industrial waste, then there are at least 52 sites with potential contamination problems. This is probably a highly conservative estimate, noting that only 16% of Class I sites even had leachate monitoring, and only 4,6% of Class II sites had monitoring.

Based on a rough figure of 52 sites requiring clean-up and based on the USA costings, possible costs for South Africa are:

• $1,664 billion (R6,074 billion) for scenario 1;
  
  
• $109 million (R398 million) for scenario 2, and;
  
  
• $343 million (Rl,252 billion) for scenario 3.

Even the smallest amount is a substantial cost for a new waste management system to deal with. In addition to this cost of remediation there are other significant backlogs of hazardous waste already within the system. These include asbestos-mining overburden, buried under soil, and other mining backlogs in the form of semi-purified concentrates containing zinc, copper, cadmium or cobalt. A variety of industries have privately managed on-site solid waste backlogs from evaporation or gravitation ponds (Department of Environmental Affairs and Tourism 1992).

Also significant are those hazardous materials still in circulation in the economy. About 228 000 tonnes of asbestos have been used since 1960 to manufacture numerous products—many of which are still in use. Thus, a large flow of asbestos-containing material will still be entering the hazardous waste stream for many years to come. A similar situation exists with respect to polychlorinated biphenyls (PCBs). Although PCBs are not used for new equipment anymore, it is estimated that about 2 000 tonnes of PCBS are still in use in existing equipment. Most users have been storing old contaminated equipment until there are adequate sites or technology able to deal with it. As with asbestos there is, therefore, an annual estimated waste stream of PCBs of about 300 tonnes despite them having been phased out of production. The cost implication of just this backlog is an estimated R350 — 400 million cost for the replacement of PCB-containing equipment (Department of Environmental Affairs and Tourism 1992).

These estimated costs may seem alarming but they are not unrealistically high. Other countries with far better histories of waste management than South Africa, albeit in the context of greater industrialisation, have arrived at similarly high figures in estimating their cleanup costs. Estimates include $10 billion for the Federal Republic of Germany, more than $1,5 billion for the Netherlands and at least $60 million for Denmark.² Calculations in the UK have suggested that $11 billion-$50 billion will be needed to clean up an estimated 50 000 to 100 000 polluted industrial sites (International Labour Organisation 1994).

² These estimates are from an OECD secretariat paper, Paris, 1986, and are cited in World Commission on Environment and Development 1987.

What has become clear through the experience of Superfund in the USA and cleanup efforts in other countries, is that remediation is costly (Davis and Hyfantis 1993). It is undoubtedly preferable, and more cost-effective, to take a preventative approach to hazardous waste management. South Africa’s potential remediation costs, although probably still at a manageable level, will use up resources that could be far better used to generate economic development. The country cannot afford to continue to bear the costs of environmental neglect. At the same time, we have the opportunity to move onto an industrial development pathway which includes as one of its integral aims, along with job creation and economic growth, a preventative hazardous waste management strategy. This needs to be built on the basis of minimising or eliminating the production and release of toxic materials into the environment.

The need for integrated pollution control

Environmentally sustainable development depends on the protection of a country’s natural resource base and on ensuring that the assimilative capacity of the environment is not exceeded. An effective pollution reduction, control and monitoring system is, therefore, vital for the future sustainable development of the country. Increasingly world attention is focusing on regulatory frameworks in which the minimisation or prevention of toxic wastes is prioritised—rather than merely the management of their disposal (Hirschborn, Jackson and Baas 1993). Even more fundamentally it is increasingly accepted that in the long-term it is necessary to reduce and eventually remove the production and use of hazardous substances in industrial systems.

One of the ultimate goals of industrial pollution control should be to change our industrial systems to one which does not depend upon hazardous materials. The emerging approach to industrial environmental management is a preventive one which focuses not on the so-called ‘end-of-pipe’ control of pollution, but on the introduction of clean technology and on changes in the processes of production.

Given current production methods and consumer demands, however, in the short-term there is still a need for mechanisms of control over the volumes and types of substances entering the environment. As outlined in Agenda 21 (Chapter 19),³ which deals with the sound management of toxic chemicals, these mechanisms include (United Nations Institute for Training and Research 1995):

• adequate legislation;
  
• information gathering and dissemination;
  
• capacity for risk assessment;
  
• establishment of risk assessment policy;
  
• capacity for implementation and enforcement;
  
• capacity for rehabilitation and remediation;
  
• effective education programmes; and
  
• capacity to respond to emergencies.

To this list we could add the need for integration of control across environmental media.

South Africa does not have these basic hazardous substances control elements in place. In fact, according to the Department of Environment Affairs and Tourism (1992) South Africa “does not possess a coherent, effective system for regulating hazardous waste”—let alone a strategy to begin minimising hazardous waste production. In the light of this 1992 report and other indications of serious flaws in the South African pollution control system, a process to develop an integrated pollution control system has been launched. The ultimate aims of this are, firstly, “holistic pollution control which should be comprehensive enough to cover all activities that impact significantly on the water, air or land environmental media, over the full-time scale of the effects of these activities” and, secondly, “integration of pollution control, which should be so organised as to consider discharges and emissions to all environmental media in the context of the effect on the environment as a whole” (Department of Environmental Affairs and Tourism 1994).

Although serious problems have been raised with the process of establishing South Africa’s integrated pollution control system (Lukey 1995), there is general support for an integrated approach to pollution control. A key problem in South African environmental control, and one which is well-recognised, is the uncoordinated fragmentation of environmental legislation and regulation between government departments and between levels of government. This situation has been recently exacerbated by the Constitution’s delegation of environmental protection to the provincial governments. There are now nine new government structures, each with some responsibility for environmental protection but each with different structures, policy responses and capacities. The potential for coordinated responses are slim without an integrated system incorporating a central role for the national government.

Apart from the integrated pollution control process there are other policy initiatives and imperatives that are having an impact on pollution control. These include South Africa’s obligations under the Basel Convention, new guidelines from the Department of Water Affairs and Forestry on the management, handling and disposal of hazardous waste (Department of Water Affairs and Forestry 1994), the environmentally sound management of dangerous materials programme of the Department of Environmental Affairs and Tourism (1995), and a range of policy initiatives being considered by the new provincial environment departments. Although some progress is being made in developing more effective approaches to the control of hazardous and non-hazardous pollutants, little attention has been paid to the question of whether there is sufficient information of a sufficiently reliable quality on which to base informed policy decisions.

The role of information in pollution control

A major impediment to environmental management in South Africa is a shortage of accessible information. Sometimes access to information is restricted, sometimes it is difficult to locate and sometimes it is in a format hard to use—but more often than not it simply does not exist. The absence of reliable environmental information has been highlighted by many of the chapters of this volume and poses a serious obstacle to effective environmental management.

Any management system of the complexity of an integrated pollution control system must be based on one that is a reliable, consistent, easily retrievable and usable. Pollution cannot be effectively controlled unless its sources are known. Future planning and resource allocation cannot take place without knowing the extent of the problem; nor can goals be set or success measured without having a system which allows progress to be monitored from year to year. South Africa lacks such an information system.

The current information situation

Nobody knows how much hazardous waste is produced in South Africa annually. There is no central database on the quantities or types of hazardous pollutants released into the environment. No government department has been tasked with providing such an overview. Furthermore, the information which is available does not provide a breakdown of who releases hazardous wastes, where it is released and its final destination.

In the public sector the two authorities responsible for pollution control are the departments of Environmental Affairs and Tourism and Water Affairs and Forestry. The Department of Environmental Affairs and Tourism and its chief air pollution control officer, in particular, are the principal authorities charged with the management of air pollution (Petrie, Burns and Bray 1992). The Department of Water Affairs and Forestry has principal responsibility for the management of water pollution (Lusher and Ramsden 1992). Furthermore, the Department of Water Affairs and Forestry is responsible for the licensing of landfill sites and, hence, has a large role to play in the control of landfilled waste—including hazardous waste. These two authorities also are the main repositories of available information on hazardous pollutant releases. In both cases the information comes primarily from their permit procedures.

According to Noble (1995), due to the method of collection, this pollutant release information is neither complete, nor in a very useful format. The air pollution data is only for so-called ‘scheduled processes’ under the Atmospheric Pollution Prevention Act 45 of 1965 and, thus, covers only permitted establishments and those substances permitted. At present there are about 2 000 permits in operation, covering about 1 200 industrial sites (Petrie, Burns and Bray 1992). Similarly, only effluent from releasers subject to a permit, and only those substances or parameters listed in that permit, are recorded by the Department of Water Affairs and Forestry. Furthermore, the format of this data is inconsistent and is not suitable for year-to-year monitoring of nationwide pollution releases, nor for analysing pollution data geographically.

In general, therefore, there is little knowledge of types, quantities or locations of a wide range of hazardous substances released into the environment. This applies to the generators of the waste as much as it does to the regulators. The 1992 Department of Environmental Affairs and Tourism study (1992b) found that in the private sector “very few industries have waste management strategies or plan their waste management before starting up”. Further, neither government authorities, nor waste facility managers have “annual statistics or databases available. Only a few operators of waste facilities and transporters of waste have detailed knowledge of the waste they handle. …Further shortcomings revealed include a…lack of information reaching decision-makers, operators and others either responsible for hazardous waste management or affected by it”.

Availability of information

Information which is held by government authorities is also not readily available to the public or even to academic researchers. Under the Atmospheric Pollution Prevention Act there is a blanket secrecy provision (section 41) which provides that no information can be disclosed without the consent of the person carrying out the undertaking unless it is for the purposes of legal proceedings arising out of the Act. The Water Act 54 of 1956 has no direct statements of confidentiality but it is the general practice of the Department of Water Affairs and Forestry not to release permit details without the consent of the pollution discharger. There are currently no general rights of public access to information on pollutant releases.

A culture of secrecy has developed among South African industries, with many loathe to divulge environmental information—especially that information which may reflect badly upon the company. This is partly due to the legal protection they enjoy, partly due to mindsets developed during the apartheid era, especially in the parastatals, and partly due to inexperience with public interaction. The Department of Environmental Affairs and Tourism survey (1992) said that a “severe limitation on the interpretation and presentation of the findings was the requirement of major generators for confidentiality”.

The fears encountered during the survey were so serious that one major industrial generator only allowed an interviewer onto the premises after ensuring that he had no pens or paper on him. The company took the notes during the meeting and forwarded them to the interviewing team many months later. So onerous were the confidentiality agreements for the study overall that all the raw data—the largest collection of hazardous waste data ever gathered in the country—was destroyed after the final report was published to ensure long-term confidentiality.

State of the nation: The Department of Environmental Affairs and Tourism survey

In recognition of the dire shortage of information on hazardous waste and of the fact that “of all the areas of environmental management, hazardous waste management has had the least attention in this country”, the Department of Environmental Affairs and Tourism initiated an investigation into hazardous waste in 1989. Its purpose was to analyse the situation and propose a regulatory system to deal with the gaps in the legislation. As the report notes, “South Africa has had air and water pollution legislation on the statute book for many years, but has only incomplete legislation relating to waste. What there is does not address the question of hazardous waste.” The final report, entitled Hazardous Waste in South Africa (Department of Environmental Affairs and Tourism 1992), although released in 1992, provides the most up-to-date and comprehensive report on hazardous waste production in South Africa.

Some of the major results of the survey are outlined below to give an idea of the scale of the hazardous waste management problem in the country. It must be borne in mind that in the uncertainty analysis of the Department of Environmental Affairs and Tourism report it states that “from the outset of the investigation, it was clear that reliable data on hazardous waste generation in South Africa would be very difficult to obtain. Even the costly survey planned was obviously not going to be able to yield a very accurate assessment of the status quo” (Department of Environmental Affairs and Tourism 1992, Volume 1: 52).

Waste was defined as the by-product from a process that is stored for three months or longer, or enters the environment or leaves the premises. This includes waste in air, water and solid waste streams. Hazardous waste was defined as any waste representing a threat to human health or the environment through risk of explosions or fires; chemical instability, reactions or corrosion; infections; acute or chronic toxicity; cancers, mutations or birth defects; ecotoxicity; or accumulation or persistence in the environment.

A hazard rating was defined under which Group 1 (high hazard waste) was waste that required the most urgent and strict control due to significant concentrations of extremely toxic constituents that are also persistent in the environment and bio-accumulative. Group 2 (moderately hazardous waste) was defined as waste with highly dangerous characteristics or that which has significant concentrations of either highly toxic constituents, or moderately toxic constituents that either persist or bio-accumulate. According to Noble (1995), one of the chief authors of the report, the hazard rating was fairly conservative in that it did not overstate the hazardousness of the waste reported.

The report found that a total of 1,89 million tonnes of hazardous waste were generated annually in South Africa. Of this 59% was carried in waste water, and 93,6% of this waterborne hazardous waste stream was cyanide-containing effluents from gold-mining. Air emissions accounted for 18% of the total and the rest (23%) was comprised of solid wastes, sludges, emulsions, tars and slurries. The waste streams and their quantities present a profile which differs substantially from that found in other countries, with the total being dominated by a few very large waste streams. These included mining and coal-burning wastes (Department of Environmental Affairs and Tourism 1992).

Table 1 below shows the industrial breakdown of the total and hazardous waste streams. The table excludes non-estimated sources, such as agriculture and forestry, domestic and trade refuse, domestic smoke, vehicle emissions and sewage sludge. The contribution of these non-point (diffuse) and unreported sources to the total hazardous waste stream is potentially very substantial. It can be seen that gold-mining dominates the total stream, with most of it being Group 2 waste. The Group 1 (high hazard waste) component of the hazardous waste stream was dominated by non-metallurgical manufacturing industries.

Pollution information systems

Given the need for better information on the production and release of hazardous pollutants, it is useful to consider approaches to the collection, management and dissemination of this type of information in other countries. This problem is not one that is unique to South Africa—many countries, particularly in the developing world, have little knowledge of their levels of pollutant releases. It is only fairly recently that even the more industrialised countries have implemented comprehensive and integrated systems of pollution monitoring and recording.

TABLE 1 Total SA hazardous waste streams—Group 1 and Group 2 waste combined (millions of tonnes per annum)

(from Department of Environmental Affairs and Tourism 1992)

This broad problem of lack of information was considered at the United Nations Conference on Environment and Development. The document arising from the conference, Agenda 21, recognised both the need for reliable environmental information and a more general right to information. In this regard it recommended that all countries establish pollution tracking and inventory systems (Young 1994). Probably the best developed example of these is the USA Environmental Protection Agency’s toxic release inventory programme, which provided some of the bases for the Agenda 21 recommendations. More recently the OECD has been developing generic guidelines for the establishment and use of these systems. The generic term for these programmes as used by the OECD, is pollution release and transfer registers, which similarly will be used here.

Pollution release and transfer registers

A pollution release and transfer register is a relatively simple concept which can easily be adapted to national environmental protection needs. Simply put “a [pollution release and transfer register] is a catalogue or register of potentially harmful pollutant releases or transfers from a variety of sources. A [pollution release and transfer register] generally includes information about releases or transfers to air, water and soil as well as about wastes transported to disposal sites. A [pollution release and transfer register] includes reports about specific species such as benzene, methane or mercury as contrasted with broad categories of pollution such as ‘volatile organic compounds’, ‘greenhouse gases’ or ‘heavy metals’” (OECD 1994).

The register is compiled from data gathered through a generally mandatory system of reporting from point source polluters. They are expected to report regularly on the quantities of their releases of chemicals from a predetermined list, plus other information useful in the control of hazardous pollution. Some systems also attempt to calculate non-point releases by means of estimates using monitoring data, statistical data and emission factors. These diffuse sources could include substantial polluters such as agriculture and transport.

Three main reasons provide the rationale for the establishment of a pollution release and transfer register: the first is the right for the public to have access to environmental information to enable them to participate in pollution control activity; the second is the need for comprehensive and accurate pollution release information for environmental management authorities; and the third is to encourage and improve pollution reduction.

Making the right to know meaningful

A pollution release and transfer register can be seen as a step towards meeting some of the key principles for sustainable development outlined in Agenda 21—specifically the principles that environmental issues are best handled with the participation of all concerned citizens and that each individual shall have the appropriate access to information to make this participation meaningful. Agenda 21 makes specific reference to the need to provide information to non-governmental organisations and civil society about accidental and routine pollution releases.

In the light of this, the USA toxic release inventory is not only important because it is the earliest and best-developed pollution release and transfer register system—it is primarily significant because of its origins in the ‘right-to-know’ movement in the USA. Public access to information was a hard-fought battle in the USA, as in other countries, with the toxic release inventory being a notable victory. In the environmental arena the initial thrust for guaranteed access to information on hazardous substances came from trade unions and other worker organisations. Their demand for entrenched worker and community right-to-know provisions was given impetus by the Bhopal disaster in December 1984, when an accidental methyl-isocyanate release from a Union Carbide plant in India killed about 2 000 Bhopal residents.

Shortly afterwards, this disaster was followed by a large pesticide release at a Union Carbide plant in West Virginia. This accident, although far less serious (about 130 people had to receive emergency treatment), brought the realisation that chemical disasters could happen closer to home. This realisation helped to further promote joint union and environmentalist pressure for a more open flow of information about potentially hazardous substances.

The Environmental Protection Agency proposed a voluntary chemical emergency programme which was rejected by the USA Congress as not being stringent enough and was replaced by legislation that imposed strict requirements on all major producers and users of toxic substances. The Emergency Planning and Community Right to Know Act, of which the toxic release inventory forms part, was a major step forwards in extending the right-to-know principle from the workplace to the general community (Robinson 1991). The Act comprises three parts: the first deals with hazard communication and requires reporting on hazardous chemical inventories; the second requires facilities to submit annual records of their environmental emissions of toxic substances; and the third establishes state and local planning committees to develop plans in response to the data generated by the first two sections (Environmental Protection Agency 1988).

All data collected under the toxic release inventory is made publicly available through a variety of means, including written and electronic media. This allows citizens and environmental groups to be aware of major sources of toxic pollutants in their neighbourhood and to compare one company’s performance against another. The resulting public pressure on companies to perform better has led to many voluntary programmes to reduce the production of waste and to dispose of what is produced in a safer manner.

Providing the basis for public participation in pollution control

Public release of the toxic release inventory has been used by grass roots environmental and community groups around the USA to oppose industrial pollution. More than 150 reports on local, regional and national hazardous pollution problems have been produced by these groups using toxic release inventory information, and these have helped to pressurise polluters to improve their environmental performance (Young 1994). The toxic release inventory data has “lent authority to people advocating changes in regulatory and corporate policy regarding toxic pollution” (Maclean 1993).

The toxic release inventory information is also the first federal database that Congress required to be released to the public in a computer-readable format. A right-to-know network was subsequently established, using a computer bulletin board system to make toxic release inventory data available to anyone wishing to collect the information electronically. This has provided the basis for numerous local activists to educate other citizens, establish advocacy groups and generate media attention to pollution problems (Maclean, 1993).

Although non-governmental organisations and public interest groups are important users and transferers of pollution release and transfer register information, it is not only these activist groups who use pollution release and transfer register information. Journalists have indicated that the publicly available information of a pollution inventory promotes increased communication among local industry officials with the public and with the press. And, in the financial sphere, pollution release and transfer register results are used by investment analysts and insurers to assess potential liabilities and risks and to compare firms’ environmental performance (OECD 1995c). These disparate users have different needs from a pollution register and this needs to be considered in the design of the system.

Information for government planning and policy

Environmental policy formulation depends on reliable and adequate information. A toxics inventory can help to provide this—distinct from any role it may have in satisfying the public’s right to know. The key proviso to remember is that an inventory cannot be seen in isolation. A stand-alone inventory will not control pollution unless supported by a regular, monitored and enforced system; public pressure; and financial incentives and political will from government. At the same time, a reliable inventory forms a crucial element of all these aspects of pollution control.

It provides the basis for state-of-the-environment analyses at a variety of spatial scales. Information about the pollution burden can then be used to assess the effectiveness of existing controls and to target priority areas and pollutants (Foran and Glenn 1994). A national pollutant inventory could provide the basic information component of an integrated pollution control system. The OECD reports that government officials “especially at regional or local levels, often use [pollution release and transfer register] results to compare with license requirements which set limits for releases. They also compare similar facilities in order to identify candidates for inspection” (OECD 1995c).

Under an integrated system an inventory approach may also help to harmonise existing reporting requirements and to reduce the reporting burden on firms. This could include the integration of national monitoring of controlled chemicals to be reported under international obligations, and mechanisms to estimate the releases from non-point sources and from small and medium-sized firms.

In addition to these functions, an inventory provides a broader range of possibilities for government. Inventories have already been used for targeted programmes for the reduction of specific priority pollutants and for help at a local level with land-use planning and licensing decisions. The USA toxic release inventory has also been used successfully by the Environmental Protection Agency to demonstrate the comparative risks of different hazardous waste management alternatives. For example, a 1993 study used the toxic release inventory to compare ‘normal’ releases reported under the toxic release inventory of a set of organic compounds with the potential mass of the same compounds emitted by hazardous waste incineration (Dempsey 1993). The study showed that, compared with 1990 toxic release inventory releases, the emissions of the incineration compounds were very small. The information served to put the risks from incineration into a context where more direct and useful comparisons of environmental impact and health risk could be made.

At a broader policy level a properly established pollution release and transfer register can aid in the process of establishing pollution release data per unit of production for various industrial sectors. This type of data is particularly important in any attempts to model the environmental impact of different growth scenarios. Releases per unit of production is dependent on the production process, on technology and on pollution abatement measures and is, thus, unique to each country. It is, therefore, important to establish these environmental factors of production for the local economy to aid in incorporating environmental impacts into industrial planning.

Finally, a pollution register can relatively easily be linked to the use of economic instruments. The use of financial instruments for the control of pollution is becoming established as an effective and equitable method of environmental management. Economic instruments are necessary components of an integrated pollution control system, both to ensure the application of the polluter-pays principle and to generate revenue for the running of the system itself. Only by the monitoring of the polluters can this principle be enforced. Pollution registers have already been used for this application: in one instance recorded by the OECD, regional officials linked pollution release and transfer register data to the taxes imposed on firms in their area with a poor record attracting higher taxes (OECD 1995c).

A driving force for pollution reduction

Possibly the most immediately apparent benefit of a pollution release and transfer register is that it can act in a number of ways—separate from direct legislative control—as a force driving targeted pollution reduction. This aspect of pollution release and transfer registers has been demonstrated conclusively already, and is one of the most exciting reasons for implementation. These ‘voluntary’ impacts that a pollution release and transfer register can have on levels of pollution releases are due to a range of different factors. These range from fears of poor public image to internal effects on organisations generating pollution to simply the provision of a benchmark to set targets. Some of the main ways in which pollution release and transfer registers have been shown to aid in pollution reduction are outlined below.

• Voluntary agreements: the 33/50 programme

Although it is generally acknowledged to have shortcomings, the toxic release inventory is also described as the most successful tool the Environmental Protection Agency has ever used to reduce emissions of toxic substances. Between 1988 and 1992 there was a 40% decline in releases of 17 priority toxic chemicals, primarily through toxic release inventory-linked voluntary reduction programmes established between the Environmental Protection Agency and companies who chose to be involved (United States 1993a, 1993b, 1994a). In real terms this means that chemical emissions declined by 272 million kilogrammes. Reduction was largely achieved through the Environmental Protection Agency’s 33/50 programme, which used voluntary targets and technical assistance to promote pollution reduction in industry. Based on a list of 17 priority toxic release inventory chemicals, the Environmental Protection Agency set the goal of a 33% reduction by 1992 and a 50% reduction by 1995. Indications are that this 50% target was reached well ahead of schedule.

Over 1 200 firms have joined the programme, benefiting from both reductions in waste materials generated and in positive publicity from the 33/50 programme (United States 1994a, 1994c). The Environmental Protection Agency says that by contacting the chief executives of the parent companies of toxic release inventory facilities that report 33/50 programme chemicals, they seek to instil a pollution prevention ethic among the highest echelons of American business (United States 1994d). The Environmental Protection Agency found that companies participating in the programme reported higher reduction levels than other USA companies, that the targeted chemicals were reduced significantly more than other toxic substances and that the number of participating companies is growing.

However, some reservations must be noted about the replication of such promising results in South Africa. Firstly, it must be recognised that the toxic release inventory is only one piece of legislation among other existing controls which strictly monitor and regulate toxic substances in the USA; for example, under the USA Pollution Prevention Act of 1992, companies also have to reveal what they are doing to prevent pollution. It is possible that such reductions in emissions may not be possible in South Africa because of the lack of infrastructure to enable and enforce compliance. A further issue that the Environmental Protection Agency points out is that larger companies are much more willing to participate, while smaller companies are more reluctant to get involved. Depending on the relative pollution impact from differently sized establishments, this could also affect the functioning of similar programmes in South Africa.

At the same time it may follow that equivalent or even larger reductions could be possible in South Africa for two reasons: firstly, our concentrated economy may mean that large companies may contribute to pollution in higher proportions than in the USA and, secondly, given our lag in pollution control and technology, the pollution baseline may be higher here, thereby making rapid reductions relatively easy.

Influencing company management

Apart from the potential of voluntary government-industry programmes, pollution inventories may have other direct effects on industrial performance. As Cairncross (1992: 291) points out, “no management tool is more powerful than information”. Company managers are often surprised by the quantities of hazardous waste that they are discharging, both in terms of the actual production costs of their waste and in terms of the environmental impacts of their production. According to Cairncross, nothing has galvanised senior management in the USA as much as the reporting requirements under the toxic release inventory. She quotes a company manager as saying “unless you measure something you don’t really control it”.

The reporting procedures under a pollution release and transfer register serve to make companies aware—generally for the first time—of the substances they are actually releasing and the potential hazards involved. They also enable companies to set corporate policy by setting reduction targets and goals for managers. Requirements that senior managers, or the chief executive officer, actually sign the pollution release and transfer register submission, also ensures that these reports are seen by top management. This serves to educate management and to demonstrate the potential effects that this information could have on the company’s profile. A major UK firm has found that the primary audience of its release data is its own workers who wish to know more about the risks of their company (OECD 1995c).

This ‘self-education’ would be particularly valuable in South Africa, where the Department of Environmental Affairs and Tourism (1992) hazardous waste survey found that most generators had never even carried out a simple mass balance of inputs and outputs and that most had “no figures available on waste generation”. Of the limitations imposed on the department’s study “the most striking to the interviewers was the widespread lack of knowledge encountered among respondents” (Department of Environmental Affairs and Tourism 1992). The company education intrinsic to a pollution register would go a long way to remedying this situation and thereby promoting pollution reduction at source and, hence, cleaner technology.

International experience with pollution release inventories

Following the success of the USA toxic release inventory scheme, several other countries have introduced pollution release and transfer registers. These include Canada, the Netherlands and Norway. The Australian government is currently going through a process of developing a national pollution inventory which is to a large extent modeled on the USA’S toxic release inventory. The OECD and the EU are also investigating these issues, as are New Zealand, Mexico and Egypt. A few examples are given below to demonstrate the various structures and approaches used.

Canada’s national pollutant release inventory

Canada has a pollution inventory called the “national pollutant release inventory”, which started collecting data in 1993. It was based to a large extent on the toxic release inventory, with some changes and additions. Under the Canadian Environmental Protection Act (Canada 1994a, 1994b), a substance that is regulated under another Act, such as a pesticide under the Pest Control Products Act, cannot be regulated under the Environmental Protection Act. This is done to avoid excessive regulatory and administrative burdens on industry. The American toxic release inventory included a lot of substances that were filtered out for this reason. Also, a number of the toxic release inventory substances are not used by industry in Canada (Beckett 1995). After all of this ’Canadianisation’, the national pollutant release inventory includes 178 substances.

The substances reported are of concern to human health or the environment—it is not strictly speaking only a ‘toxics’ list. In the first year a total of 1466 facilities filed reports in a process described as successful and well-received (Environment Canada 1995). As in the toxic release inventory some facilities are excluded, such as mining, wholesale and retail facilities and fuel storage. The inventory goes further than the toxic release inventory in that it estimates the releases of listed substances from mobile sources and from fuel distribution. It also includes sections on estimates of inventories of greenhouse gases and common air contaminants.

The establishment of the national pollutant release inventory was accomplished with the support of a multi-stakeholder advisory committee which included representatives from industry, labour, environmental organisations and from provincial ministries and federal departments. The stakeholders recognised that the national pollutant release inventory could change over time and could be improved and refined to meet new needs and objectives. As with the toxic release inventory, a range of supporting materials have been developed by Environment Canada to aid in the reporting and dissemination of the national pollutant release inventory data. These include (Environment Canada 1995a, 1995b, 1995c, 1995d):

• pamphlets on common questions;
  
  
• guides to reporting;
  
  
• computer-based reporting and reporting software user guides; and
  
  
• summary reports of the salient collected and aggregated information.
  
  
• These materials make the inventory easily understandable and accessible, and are crucial to its successful functioning.

The UK’S programme under Her Majesty’s Inspectorate of Pollution

The UK’s pollution release and transfer register, termed the “chemical release inventory”, uses monitoring information that is already collected as part of permit requirements under the country’s integrated pollution control system. This information is then made available centrally in a more accessible and useful format. Those facilities regulated by the integrated pollution control system are mainly the larger industrial sites which are the main contributors to the chemical release inventory. This has been a point of concern in the UK, with some groups calling for a broader scope for the inventory. As it stands, the chemical release inventory is really a site-by-site inventory rather than a pollution inventory as such (McGlinchy 1995b).

The process of establishing the chemical release inventory raised many of the issues dealt with above. A key issue debated was the inclusion of individual names of companies and a ranking of the worst polluters—which was called for by the Institution of Environmental Health Officers. The institution also stressed the importance of presenting the information in an interesting and user-friendly way, and the importance of using the inventory in conjunction with other elements of government policy, such as the national sustainable development plan. In particular, the institution suggested that the inventory should be used to set targets for local emissions reductions and to identify pollution black spots’ (Institution of Environmental Health Officers 1993).

Australia’s national pollution inventory

The establishment of the Australian national pollution inventory was announced in 1992. Following this statement, A$5,9 million was committed to developing the inventory, with the main justification for it being the public’s right to know. Apparently there is strong grass roots pressure in Australia for this kind of information. The inventory was also linked to Australia’s commitments under Agenda 21 (McGlinchy 1995a). The proposal is that the national pollution inventory be made up of six information modules consisting of a toxics release register, existing pollution release information, urban transport and smog issues, solid non-hazardous wastes data, intractable wastes information and greenhouse gas emissions data.

There is a committee overseeing the development of the national pollution inventory with representatives from the Commonwealth, state and local government, industry, small business, non-governmental organisations and community groups. One of the main priorities for this group is to develop the list of species to be reported. There is no agreed list of what should constitute the inventory at this time, and opinions vary quite markedly as to what should be included. The split has been summed up as industry wanting nothing’ and community groups wanting ‘everything on the list. The initial list is likely to include aggregated groups of chemicals rather than specific substances.

One of the problems in drafting legislation for the national pollution inventory is the sometimes difficult ways that responsibilities are split between state and Commonwealth governments. Whatever happens, it is recognised that there must be cooperation from state governments for the national pollution inventory to work. This provides a useful lesson for South Africa, which faces similar issues.

In the short-term, the inventory may consist of a central and publicly accessible register of all information that is already required to be reported as part of state and local body discharge permits. Another major priority is to develop ‘estimating techniques’ for emissions so that small companies, in particular, do not have to install expensive monitoring equipment.

The Australian situation sounds fairly similar to South Africa’s situation. Several interesting issues have been raised in the Australian process which appear to be apposite to South Africa and which probably will have to be debated here as well. These include the following:

• industry is keen to include non-point source emissions, such as households and agriculture;
  
  
• there is strong pressure to require all companies using listed substances to report, not just the larger ones. There is general agreement that there is no logical reason for the proposed cut-off at 10 persons (based on the USA toxic release inventory) and this limitation will probably be dropped;
  
  
• the most appropriate method of facilitating community access to the information is as yet unresolved. There is a distrust of local government by some community groups, despite this being the logical place to put the information; and
  
  
• at which regional units should data be reported? Some companies are very wary about the inventory using too small a unit to record data, as this may allow identification of specific companies, whereas other groups are saying that this is precisely what the inventory is for.

The main lesson that can be learnt from the Australian experience is the need for a thorough, inclusive process of establishing an inventory. The Australian Environmental Protection Agency held a series of national workshops, and allowed written submissions as a response to a national pollution inventory discussion paper (Australia 1994). The agency then established a national pollution inventory reference group which includes representatives from the Environmental Protection Agency, the state governments, local government, community and conservation groups, industry associations, trade unions and a scientific adviser. They also used a series of trials and pilot projects of selected aspects of the national pollution inventory, such as data dissemination, substance lists and database management (Australia 1995). Special attention was also given to areas away from the large cities to establish community desires and needs from an inventory in smaller towns and rural areas.

The OECD and United Nations Institute for Training and Research’s guidance to governments

The OECD has been preparing a document entitled “Guidance to governments” on pollution release and transfer registers. It has been attempting to establish generic guidelines which governments can use as the basis for assessing the need for a register and for establishing one if this is seen as important. The process is aimed at being inclusive and includes developing, as well as OECD countries, non-governmental organisations and industry. It appears to be a useful process, with the basic principles of pollution release and transfer registers being outlined in the documentation, as well as the experience of countries with existing pollution registers being reflected.

The United Nations Institute for Training and Research has used the material from this process in a programme targeted at helping developing countries to improve their pollution information systems. The institute has initiated a successful process in Mexico (Halpap 1995) where the concept of a pollution release and transfer register has been accepted. Currently, some small-scale pilot projects are being conducted in Mexico to assess the viability of the approaches adopted and to refine the system prior to instituting it nationally. The institute stresses the importance of an inclusive process in the set-up phase of a pollution release and transfer register to ensure its support by all stakeholders and to ensure its success. The Mexican process will be particularly useful for South Africa to examine because Mexico is the first developing’ country to begin instituting a national pollution inventory. Its experience may be more appropriate for South Africa to learn from than that of the more industrialised nations.

A pollution release inventory in South Africa?

The need for an improved data collection and management system for hazardous waste was strongly raised in the Department of Environmental Affairs and Tourism’s report (1992) on hazardous waste. The current integrated pollution control process also makes provision for consideration of information needs. Given the clear need for improved and freely available information, it seems appropriate to initiate a process towards the establishment of a pollution register in South Africa, with the form and geographical extent of such a register depending on the objectives set for it. As early as 1992 the department noted that:

[A]t present there is a severe shortage of information for planning, decision making and public information. For all facets of environmental management to be effective, a database is urgently needed. It will be needed to aid regulation, both legislation and its implementation, research and strategic planning, commercial enterprises, and perhaps to provide a 24-hour regional emergency service. It will also be needed to provide data for reporting to the Basel Convention and other international bodies.

The department’s report goes on to recommend in fairly general terms the establishment of a national database of types and quantities of hazardous waste being generated. It suggests that this database include the results of research into the impacts of hazardous substances, recycling methods and clean technology. It also suggests linking this to an “information clearing-house” which will publish documents on hazardous waste issues of public concern, carry out public education, respond to public queries and provide a means for the public to articulate their views to decision-makers. A principle underlying this proposed information system is that “access to information should be as free as possible”.

A pollution release and transfer register could provide the backbone for this type of database, with the more ambitious aspects being linked to it at a later stage. Prior to the establishment of a pollution inventory of this nature, a number of issues will need to be more thoroughly considered and debated. These include determining:

• the prime objectives of the inventory;
  
• the list of substances to be included;
  
• who needs to report;
  
• who collects and manages the information;
  
• how the data is disseminated; and• how it is to be financed.

There are numerous issues that will make the establishment of an inventory substantially different in South Africa from elsewhere, suggesting caution in merely adopting an approach already used elsewhere.

The special circumstances relate both to our industrial base and to our social context. For example, in the USA mining and utilities are excluded from the toxic release inventory, whereas these sectors are major contributors to the pollution load in South Africa. The increasing number of small and medium-sized enterprises in South Africa also pose particular constraints on an inventory. Many of these firms may need technical assistance in assessing and reporting their releases, and their large numbers will raise the administrative burden of an inventory. The particular needs and problems of this sector would need to be dealt with during the installation of a pollution release and transfer register.

The dissemination of data will also present special problems. Widespread publication in all 11 official languages would be extremely expensive. South Africa would also have difficulty in relying on computer networks as a viable solution. South Africa has nine computers per 1000 citizens, compared to 265 per 1000 in the USA and 134 per 1000 in the UK (Young 1994). This does not necessarily mean that computers and Internet-based information provision will not be a useful and cheap method to use—it merely points to the particularities of the South African situation.

The need for an inclusive process of establishment

Possibly the most important lesson that South Africa can learn from the international experience is the need for a thorough process of consultation in the development of a pollution release and transfer register. For a register to be successful it needs to be accepted as useful by all stakeholders: those doing the reporting (primarily industry), the authorities managing the system and interested and affected parties from the public. Without agreement on the objectives and scope of the inventory from these stakeholders it will be unable to fulfil its potential. At worst it will simply not function due to inadequate reporting and public disinterest.

Recommended course of action

The current South African integrated pollution control process does not provide a successful model for a participatory environmental policy development process. However, there have been some inclusive policy development processes in other areas that have achieved consensus or compromise policies supported by the relevant stakeholders. It is entirely feasible to do the same with a pollution release and transfer register consultation process, given the correct political will and attitude.

Such a process need not be too complicated, although it would have to incorporate a fairly large number of elements. These have been outlined by the OECD and follow in a logical fashion. The first step is to establish a multi-stakeholder group that is representative and legitimate. It can then embark on a process which will consider the following elements in an incremental process: the establishment of precise goals and objectives, the agreement on proper definitions of terms (such as ‘release’ and ‘transfer’), a decision on the species list and on the scope of the inventory (such as point or non-point releases) and public sector reporting. The administrative details then need to be agreed on: which authorities manage the process, reporting thresholds, method and ease of reporting and data dissemination.

A range of potentially controversial factors will have to be considered in the process, but these need not be stumbling blocks as they have all been satisfactorily resolved elsewhere. Such issues include sanctions for non-reporting, the methods of dissemination, who pays for the inventory and issues of confidentiality. These last two will be briefly looked at to demonstrate how they have been handled in other systems.

Confidentiality

An issue that is often raised by companies in relation to pollution release and transfer registers is the need to protect trade secrets or other industrially sensitive information which may be breached by a pollution release and transfer register. This has been dealt with in the legislation establishing release inventories in a number of countries. Under the USA toxic release inventory, reporters can only claim confidentiality for chemical identity—trade secret claims must be fully substantiated and non-frivolous and a highly ranked company official must sign the claim. The Environmental Protection Agency can impose strict penalties if these claims are shown to be false (United States 1988).

In most other national pollution release and transfer registers similar requirements are incorporated, which place the onus on reporters to provide evidence that their disclosure may cause industrial or commercial harm (OECD 1995b). In the establishment of pollution release and transfer registers there is a tendency for industry to request that data is aggregated to such a level that individual firms cannot be identified. Most inventories, however, have accepted that many of the benefits of the system would be lost if firms did not have the pressure of this disclosure on them.

The costs of establishing a pollution release and transfer register

Given the simplicity of a pollution release and transfer register system, the administrative costs for the authorities are fairly low. There are also other costs to be borne in mind, such as the time companies spend gathering the required information and filling out the forms. The fact that a time and expense burden falls on firms, conforms to the polluter-pays principle, but is, nevertheless, one of the issues of concern to industry and should be minimised. The administrative burden for governments depends on the scope and complexity of the system and of the levels of checks and balances built in, but some indications and estimates of potential costs can be made.

The World Wildlife Fund (1994) has made some preliminary estimates of the minimum resources needed by national governments to establish a toxic chemical inventory. In a country with 1200 facilities reporting waste streams and product stream data, with an average of eight chemicals each, it estimates the following figures:

• to establish the inventory using a system developed from scratch would require about two microcomputers and eight-nine person years; and
  
  
• to establish an inventory based on an international model and software would require two computers and five-six person years.

The estimate, therefore, is that a small team could establish an inventory with minimum resources in about one-two years.

The full Environmental Protection Agency toxic release inventory programme has a permanent staff of 65, with additional people employed seasonally for data entry. It costs the Environmental Protection Agency about $19 million a year, which works out at about $240 per reporting plant. The estimated time for respondents to fill in the returns is 50 hours; there are an average of 3,5 returns per facility, that is, an average of 175 hours per facility. In the UK the establishment of the chemical release inventory was substantially cheaper as it relied on information already provided by facilities. The start-up costs were about £250 000, with annual running costs estimated at £62 500 (McGlinchy 1995).

The Australian national pollution inventory process has estimated costs at A$l,9 million for the inventory as a whole, with costs of A$ll 000 per facility for all the annual reports. The polluter-pays principle seems to have been accepted in South Africa by all parties, as one of the guiding principles of environmental management. In this light the argument can be advanced that reporters should contribute financially, on a pro rata basis, to the costs of an inventory. Other financing options, such as sharing the expense between provincial and national government, could also be explored. It does not appear that cost is too large an impediment, with most pollution release and transfer registers being fairly inexpensive and cost-effective.

Conclusion

All indications are that it is useful and necessary to establish a pollution inventory of some type in South Africa, one which can be used for supporting environmental improvements by:

• setting priorities;
  
• for encouraging voluntary reduction measures;
  
• allowing the tracking of progress in pollution reduction;
  
• for supporting regulatory initiatives; and
  
• for supporting citizens’ action and participation.

If a pollution release and transfer register is established, it makes sense to tailor it to the specific needs of the country and to use it to include as much useful information as is practical. Once an entire reporting system is being put in place, the marginal costs of gathering new information may be relatively small while the benefits of new information may be great.

In South Africa’s new democracy the right-to-know aspects are particularly important. Not only are they important in and of themselves to ensure that environmental management is open and accountable, but the sense that all social and economic actors are responsible for the environmental costs of their actions is an important one to engender. Ensuring that environmental impacts are openly reported helps this process enormously, and is one of the active steps that the country can take in meeting the sustainable development imperatives of Agenda 21.

An inventory is only a part of a pollution control system, and only one aspect of developing an environmentally sound industrial base. Only a multi-pronged strategy will ultimately achieve the goals of sustainable development. Whatever this strategy finally includes, information will be an essential aspect of it. Again and again researchers working on this volume have come up against a blank wall of unavailable information. Sometimes there was reluctance or downright refusal from industries to divulge environmental information; sometimes it was the authorities who were reluctant—but often the information is simply not there. Information—that vital commodity of the 1990s and beyond—is in short supply and this is hampering the protection of that other increasingly vital commodity— our natural environmental resources.

References

Australia, “National pollutant inventory update”, Environment Protection Agency, 1994.

Australia, “National pollutant inventory update”, Environment Protection Agency, 1995.

Beckett, A., personal communication, senior contaminants biologist, Environment Canada: toxic substances division, Prairie and northern region, Edmonton, Alberta, Canada, 1995.

Cairncross, E, Costing the Earth: the challenge for governments—the opportunities for business, Boston, Harvard Business School Press, 1992.

Canada (1994a), “Canadian Environmental Protection Act”, R.S. 1985, c. 16 (4th Supp.), July 1994.

Canada, (1994b), “Notice with respect to substances in the national pollutant release inventory”, Extract Canada Gazette, Part 1,26 February 1994, Ottawa, Queen’s Printer for Canada, 1994.

Davis, K., and Hyfantis, G., “Costs of the toxic legacy—lessons from the remediation of superfund sites”, in T. Jackson (ed.), Clean production strategies: developing preventive environmental management in the industrial economy, Stockholm Environment Institute, Boca Raton, Lewis Publishers, 1993.

Department of Environmental Affairs and Tourism (1992a), “Hazardous waste in South Africa”, Volumes 1-5, Pretoria, Department of Environmental Affairs and Tourism, 1992.

Department of Environmental Affairs and Tourism (1992b), “Hazardous waste in South Africa: executive summary”, Pretoria, Department of Environmental Affairs and Tourism, 1992.

Department of Environmental Affairs and Tourism, “Integrated pollution control: project framework and plan describing the strategic process to develop a national holistic policy”, Pretoria, Department of Environmental Affairs and Tourism, June 1994.

Department of Environmental Affairs and Tourism, “The letter from Geneva”, Muniviro, 12(1), 15, 1995.

Department of Water Affairs and Forestry, “Waste management series: minimum requirements for the handling and disposal of hazardous waste”, Pretoria, Department of Water Affairs and Forestry, 1994.

Dempsey, C., “A comparison of organic emissions from hazardous waste incinerators versus the 1990 toxics release inventory air releases”, Air and waste, October 1993,43,1374-1379,1993.

Doeleman, J., “Employment concerns and environmental policy”, in A.S. Bhalla (ed.), Environment, employment and development, International Labour Office, Geneva, World Employment Programme, 1992.

Environment Canada (1995a), “The national pollutant release inventory 1993—summary report”, Canadian Environmental Protection Act, 1995.

Environment Canada (1995b), “Questions and answers for the 1994 national pollutant release inventory”, Canadian Environmental Protection Act, 1995.

Environment Canada (1995c), “Are you required to report?—national pollutant release inventory”, Canadian Environmental Protection Act, 1995.

Environment Canada (1995d), “A guide to reporting to the national pollutant release inventory”, Canadian Environmental Protection Act, 1995.

Foran, J., and Glenn, B., “Criteria to identify chemical candidates for sunsetting”, New Solutions, Spring 1994.

Halpap, A., personal communication, coordinator: training programme in chemicals and waste management, Geneva, United Nations Institute for Training and Research, 1995.

Hirschborn, J., Jackson, T, and Baas, L., “Towards prevention—the emerging environmental management paradigm”, in Jackson, T., (ed.), Clean production strategies: developing preventive environmental management in the industrial economy, Stockholm Environment Institute, Boca Raton, Lewis Publishers, 1993.

Institution of Environmental Health Officers, “IEHO response to proposed chemical release inventory”, Waste & environment today, 6(3),17,1993.

International Labour Organisation, World Labour Report, Geneva, International Labour Organisation, 1994.

Lukey, P, “Integrated pollution control: desperately seeking credibility”, On track, August-September 1995.

Lusher, J., and Ramsden, H., “Water pollution”, in Fuggle, R. and Rabie, M. (eds), Environmental management in South Africa, Cape Town, Juta, 1992.

Maclean, A., “Gathering evidence on toxic pollution using TMdata”, New solutions, Summer 1993.

McGlinchy, I. (1995a), personal communication, pollution and risk management directorate, Ministry of the Environment, New Zealand, 1995.

McGlinchy, I. (1995b), “Development of a release inventory in New Zealand”, pollution and risk management directorate, Ministry of the Environment, New Zealand, unpublished document, 1995.

Organisation for Economic Cooperation and Development, “Usefulness of instituting a national pollutant release and transfer register”, draft Chapter 1 of pollution release and transfer register guidance to governments document, Pollution Prevention and Control Group, Paris, OECD, 1994.

Organisation for Economic Cooperation and Development (1995a), “Data management and reporting for a national pollutant release and transfer register”, draft Chapter 3 of pollution release and transfer register guidance to governments document, Pollution Prevention and Control Group, OECD, Paris, 1995.

Organisation for Economic Cooperation and Development (1995b), “Dissemination and use of pollution release and transfer register data and results”, draft Chapter 4 of pollution release and transfer register guidance to governments document, Pollution Prevention and Control Group, Paris, OECD, 1995.

Petrie, J., Burns, Y, and Bray, W, “Air pollution”, in Fuggle, R., and Rabie, M. (eds.), Environmental management in South Africa, Cape Town, Juta, 1992.

Robinson, S., Toil and toxics: workplace struggles and political strategies for occupational health, Berkeley, University of California Press, 1991.

Rogerson, C., “Environmentally hazardous industry in South Africa: a spatial view”, Geojournal, 22(3), 1990.

United Nations, Agenda 21, Rio de Janeiro, United Nations Conference for Environment and Development, 1992.

United Nations Institute for Training and Research, “Preparing a national profile to assess the national infrastructure for management of chemicals: a guidance document” (pilot project version), Geneva, United Nations Institute for Training and Research, 1995.

United States Environmental Protection Agency, Chemicals in your community: a guide to the Emergency Planning and Community Right-to-Know Act, Washington DC, Environmental Protection Agency, 1988.

United States Environmental Protection Agency (1993a), Environmental Protection Agency’s 33/50 program: fourth progress update, Environmental Protection Agency 745-R-93-005,1993.

United States Environmental Protection Agency (1993b), EPA’s 33/50 program: third progress update, Environmental Protection Agency 745-R-93-0001,1993.

United States Environmental Protection Agency (1994a), 33/50 program company profiles: reduction highlights, Environmental Protection Agency 745-K-94-017,1994.

United States Environmental Protection Agency (1994b), EPA’s 33/50 program company profiles: Acme Metals Incorporated, Aladdin Industries Inc., Aldan Rubber Company, Carpenter Technology Corporation, Dexter Shoe Company, Douglas & Lomason Company, HADCO Corporation, Johnson & Johnson, Olin Corporation, Parker Hannifin Corporation, Printed Circuit Corporation, Raytheon Company, U.S. Steel Group, 1994.

United States Environmental Protection Agency (1994c), EPA’s 33/50 program: fifth progress update, Environmental Protection Agency 745-R-94-002,1994.

Waste-tech, “The voice of reason”, unpublished statement, Johannesburg, Waste-tech (Pty) Limited, undated.

World Commission on Environment and Development, Our common future, Oxford, Oxford University Press, 1987.

World Wildlife Fund, The right to know: the promise of low-cost public inventories of toxic chemicals, Geneva, World Wildlife Fund, 1994.

Young, J., “Using computers for the environment”, in State of the World 1994, London, Earthscan, 1994.

Newspaper articles

Moon, M, “Prosperity brings problem of more hazardous waste”, Business Day, Monday, 22 March, 1995.

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