Hazardous Waste Management Policy. - du

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Hazardous Waste Management Policy.

Document No: Revision:

du-HSE-PO-004 1.0

Copyright © by Emirates

Integrated Telecommunications

Company (PJSC)

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Document Owner

Department: HSSE Division: Human Resources & Shared Services

Document Number du‐HSE‐PO‐004, Rev. 1.0

Document Version Control

Version Release Date

1.0 December 2011

Version 1.0 Release

Name: Role: Signature:

Prepared By: Daxita Rajcoomar HSE Compliance Manager

Reviewed By: Margareta Larssen Senior Manager Finance Policies & Procedures

Mirzah Shujaat Ali Manager Quality Control and Supplier Performance Evaluation

Approved By:


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Contents 1. Purpose .................................................................................................................................................. 4

2. Scope………… .......................................................................................................................................... 5

3. Introduction ........................................................................................................................................... 5

4. Roles and Responsibilities ..................................................................................................................... 9

5. Hazardous and Electronic Waste Management .................................................................................. 11

5.1. Security Requirements ..................................................................................................................... 11

5.1.1. Functionality Test and Data Destruction ....................................................................................... 11

6. Waste Management Hierarchy for Hazardous Substances and E‐waste Handling ............................ 12

6.1. The hierarchy of Control for Hazardous Substances/E‐waste ......................................................... 12

6.1.1. The following procedures are mandatory when Handling/Disposing of Hazardous Substances . 13

6.1.2. The following procedures are mandatory when Handling Electronic Wastes for Disposal ......... 15

6.2. The following Re‐used Options are to be considered ..................................................................... 15

6.2.1. Selling to third parties ................................................................................................................... 15

6.2.2. Sold/Donated to Internal Staff ...................................................................................................... 17

6.3.The following recycle options are to be considered ......................................................................... 17

6.3.1. Items Sold to Third Parties ............................................................................................................ 18

6.4. The following Destruction and Final Disposal Requirements are to be considered ........................ 18

6.4.1. The Physical destruction shall encompass the following requirements: ...................................... 19

6.4.2. The final disposal practices shall encompass the following requirements: .................................. 19

7. Third Party Selection and Approval Requirements ............................................................................. 19

8. Financial Gains on Waste Items: ......................................................................................................... 20

9. Reviewing the Policy ............................................................................................................................ 21

10. Definitions, abbreviation and acronyms ........................................................................................... 21

11. References……………………………………….…………………………………………………………………………………………..24


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Hazardous Waste Management Policy.

1. Purpose This policy is an extension to our HSE policy which is set to manage our impact on the environment. The Hazardous Waste Policy has been developed to mandate that; the disposal of the mentioned waste be done in an environmentally friendly and sustainable manner at all times. The purpose of this policy is also to provide guidance on the correct procedure for disposing of hazardous waste; defined as electrical/electronic waste (E‐waste) and other hazardous substances in an environmentally friendly manner. This ensures that adequate measures are put in place when items, both electrical and electronic become obsolete within our organisation; ensuring such hazardous substances are re‐used, recycled or disposed of in an environmentally friendly manner. In addition to this, maintaining legal compliances during the disposal of hazardous substances/waste. Furthermore providing the following commitment:

1. Reduced environmental impact. Proper management of hazardous and electronic waste/substances.

2. Strive to re‐use and recycle at every opportunity where it is reasonably possible; as defined

within this policy.

3. Products which are defined as ‘good state of repair’ shall either be re‐sold or refurbished by the appropriate third parties.

4. During the collection, transportation and final disposal of these items, suppliers will only be

considered if they meet minimal environmental, health and safety requirements.

5. Strive to improve environmental sustainability by reducing carbon footprint through proper management of hazardous waste.

6. Ensure compliance to statutory requirements as far as reasonably practicable; such as our

corporate governance requirements and our commitment to our HSE policy.


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7. Encourage suppliers and contractors to adopt cleaner technologies and products with low or no impact to the environment.

8. Demonstrate leadership to the community and stakeholders on sustainable practices through

proper management of hazardous waste.

2. Scope

This document applies to all whom handle hazardous substances; electrical and electronic waste either within an organization or as a third party supplier. Including hazardous waste identified as either being obsolete and/or end of life wastes (e.g. used oils, diesel, and chemicals, beyond economic repair).

3. Introduction What is hazardous waste? An in‐organic/organic element/compound, which because of its toxicological, physical, and/or chemical properties may give out harmful, acute or chronic impacts on the health of humans and the environment. This can be generated from a variety of activities and may take the form of liquid, sludge, gas or solid. A few examples of hazardous waste defined by the Environmental Protection Agency (EPA) are categorized as follows: 1. Flammable liquids, such as non‐halogenated solvents 2. Corrosive liquids, such as strong acids and bases 3. Solid oxidizers 4. Wastes that contain heavy metals and halogenated organics 5. Greases and oils 6. Electrical and Electronic items Electrical and electronic waste contains both valuable and hazardous material requiring methods such as specialized segregation, collection, transportation, treatment and disposal.


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The following sections within this document show how to manage such items ensuring an environmentally friendly and safe disposal. Toxic components E‐waste is known to contain toxic elements which require safe handling (refer to table below). While some naturally occurring substances are harmless in nature, their use in the manufacturing process of electronic equipment, often results in altered compounds which become hazardous (e.g. Chromium becomes Chromium VI).

Substance Occurrence in E‐waste

Halogenated compounds

PCB (polychlorinated biphenyls) Condensers and transformers.

TBBA (tetrabromo‐bisphenol‐A) PBB (polybrominated biphenyls) PBDE (polybrominated diphenyl ethers)

Fire retardants for plastics (thermoplastic components, cable insulation) TBBA is presently the most widely used flame retardant in printed wiring boards and casings.

Chlorofluorocarbon (CFC) Cooling unit and insulation foam.

PVC (polyvinyl chloride) Cable insulation.

Heavy metals and other metals

Arsenic Small quantities in the form of gallium arsenide within light emitting diodes.

Barium Getters in CRT.

Beryllium Power supply boxes which contain silicon controlled rectifiers and x‐ray lenses.

Cadmium Rechargeable NiCd‐batteries, fluorescent layer (CRT screens), printer inks and toners and photocopying‐machines (printer drums).

Chromium VI Data tapes and floppy‐disks.

Lead CRT screens, batteries and printed wiring boards.

Lithium Li‐batteries.

Mercury Fluorescent lamps that provide backlighting in LCDs, in some alkaline


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The following list gives a selection (not all toxic substances found in E‐waste) of the most commonly found toxic substances in E‐waste. Valuable Components The recovery of a specific material is driven by its economic value. Primarily found in precious metals and other metals but which may also include plastics and glass. Precious and scarce materials account for only a small percentage of the total weight of the electrical/electronic. These consist of ferrous 50%, non‐ferrous metals 13%, plastics 21%, glass, wood, plywood, printed circuit boards, concrete, ceramics, rubber and other items. Non‐ferrous metals consist of metals such as copper, aluminum and precious metals e.g. silver, gold, platinum, palladium etc. Legal Compliance Requirements UAE legislations apply to all users and third party suppliers which transport, re‐use, recycle or dispose of E‐waste.

batteries and mercury wetted switches.

Nickel Rechargeable NiCd‐batteries or NiMH‐batteries and electron gun in CRT.

Rare Earth elements (Yttrium, Europium)

Fluorescent layer (CRT‐screen)

Selenium Older photocopying‐machines (photo drums).

Zinc sulphide Interior of CRT screens, mixed with rare earth metals.

Others

Toner Dust Toner cartridges for laser printers/copiers.

Radio‐active substances ‐ Americium

Medical equipment, fire detectors, active sensing element in smoke detectors.


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If the intent is to export hazardous waste, the relevant party shall comply with all requirements of the Federal Environment Agency (FEA) and in addition to the Basel Convention protocol on the Control of Trans boundary Movement of Hazardous Wastes and their Disposal. Waste Electrical and Electronic Equipment Directive (WEEE) Restriction of Hazardous Substances Directive (RoHS). There are specific European mandates on Waste Electrical and Electronic Equipment (WEEE) and Restriction of Hazardous Substances (RoHS) as in the order already mentioned in 2003. The WEEE directive sets first priority to prevent wastage of all electrical and electronic equipment. In addition to this, the re‐use, recycling and other forms of recovery of such wastes are to be set‐forth in order to reduce its disposal. This directive also seeks to improve the strain on the environment caused by its operators whom are involved in the life cycle of electrical/electronic equipment. E.g. producers, distributors, consumers and in particular those operators directly involved in the wastage process. Thus mandating all manufacturers of electric and electronic devices, including those of ICT equipment, to accept and properly recycle all end‐of‐life equipment. The RoHS directive mandates that all six hazardous substances be removed from electrical and electronic equipment, including ICT equipment. Some substances may be present at certain levels as long as they are declared. The six substances are: 1. Cadmium (Cd) 2. Hexavalent Chromium (CR VI) 3. Lead (Pb) 4. Mercury (Hg) 5. Polybrominated biphenyls (PBB) 6. Polybrominated diphenyl ethers (PBDE) The EC Directive affects operators in more than one way. For example, operators whom are not responsible for the proper recycling of the product (EEE) (equipment bought before 13 August 2005) are then responsible for the proper disposal of such waste. In the case that an operator gives its WEEE to other parties; the concerned must ensure that the receiving entity is a registered waste carrier or approved person/organization.


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Lastly they must also retain relevant records to demonstrate compliance of proper waste management. For example, waste transfer note and/or hazardous waste consignment note proving the equipment/hazardous waste has been disposed of in a suitable facility, treated and recycled in an environmentally friendly way.

4. Roles and Responsibilities Requestors and business owner(s) It is the responsibility of each requestor/business owner(s) to follow the Finance Departments Disposal Process for the write off of items that have become obsolete. In conjunction to the above write off process, the requestor/business owner(s) strictly adheres to the bellow policy. Each requester/business owner(s) ensures adequate planning is done to follow through with special environmental precautions during all disposal processes. The organization is to fully state via the Procurement and/or Financial Review Stages all necessary costs involved for its environmentally friendly disposal process. For example, if there are hazardous substances for disposal then applicable permits and fees must be paid for any landfill and/or incineration process. In addition to this certain items may require handling/safety precautions during transport (this may involve shipments to other countries for disposal/recycling) which also must be accounted for. The respective business owner(s) shall ensure the following is adhered to: 1. State within the approval stages, whether such items are in good state of repair and/or can be

re‐used or re‐sold. This also prevents environmental strain of landfill disposal.

2. Ensure that if the parts of an item/material are hazardous, specific instructions are mentioned during the procurement stage, as this ensures items are handled safely.

3. Fully ensure that the below environmental requirements are reviewed to safely manage and control the disposal methods of all Hazardous/E‐waste items, prior to completing the Finance Asset Disposal process. This will then allow the user to clearly indicate in the finance disposal write off process all the necessary actions that need be taken.

4. Provide the HSSE Department with a list or certificates of all weights, items that was re‐used, recycled and/or disposed of safely.


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It is the responsibility of the Finance Department to: Ensure asset write offs are as per all pre‐defined Policies and Processes. It is the responsibility of the Supply Chain to: Act upon the approvals solely based on the Finance Asset Write‐off Policy Process. In doing so, Supply Chain shall also ensure that appropriate third party suppliers are chosen based on the following criteria.

1. The ability to address the scope of services/work and type of materials requested/needed for proper disposal.

2. That the relevant third party companies meet all environmental requirements: - ISO 14001 certified or other applicable certifications that reflect environmental

compliance. - Such companies must provide a Health and Safety plan for its safe removal and

disposal. There should be a specific environmental plan that discloses how such items will be reused or recycled or safely disposed off with minimal to zero impact on the environment.

- Ensure compliance with UAE regulations for the handling of Hazardous and E‐wastes. - Ensure compliance through certifications for the removal and shipment of

hazardous/e‐wastes to other countries where applicable and compliance to EC directives and Basel convention on WEEE items or RoHS products.

- Provide suitable certificates or written confirmations for the wastes disposed off (safe destructions certificates and or recycle certificates).

- Where the above requirements cannot be attained, then required approvals from the HSSE department shall be obtained to continue with selected vendors.

3. Ensure that all records of its safe disposal are sent to the business owner and HSSE department for record purposes.

4. Notify the HSSE department with such relevant request that require approvals or environmental compliance verifications.

Supply Chain are responsible for ensuring that during the sourcing process for suppliers, the same are to quote/tender for the environmentally friendly and safe removal of all hazardous waste material on du’s premises. It is imperative that a consistent tracking of quantities disposed of are logged/documented during all the stages of the environmentally friendly removal/disposal process by the requestor, as this will be


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reported against du’s yearly corporate governance requirements. The user is to clearly specify such requirements during the Supply chain process. Where such information is provided by the supplier at the completion of services, then supply chain is to communicate such information to the relevant requestor and HSSE departments respectively. AMCA and Other Business Stakeholder(s) It is the responsibility of each AMCA and Business Stakeholder(s) to determine the needs of such items and/or its appropriate action; along with following the defined process stipulated by this clause and Finance Policy. These departments are to also coordinate with Supply Chain, HSSE and/or the approved third parties for the safe removal of hazardous items/E‐ waste from du’s premises. Implementation and Governance of this Policy An internal communication regarding this policy will be made to du employees, external suppliers, stakeholders and other interested parties. It is the responsibility of the department(s) within Corporate Services (Supply Chain and HSSE) to implement such policies during all disposal stages/processes.

5. Hazardous and Electronic Waste Management This shall be read in conjunction with the Sustainability Procurement Policy (HSE‐du‐PO‐002), in terms of re‐use and recycle requirements.

5.1. Security Requirements

Prior to disposal of such items, it is the responsibility of the required business owner(s) to ensure that all information considered confidential shall be removed. This can also be included in the disposal process by third party vendors that provide the required Data Destruction services using approved software systems.

5.1.1. Functionality Test and Data Destruction

1. Data found on refurbished equipment shall be handled by refurbishers. These must employ tools

and processes that meet or exceed du’s Data Destruction requirements. Equipment which fails to meet this standard or is pre‐sorted to be recycled shall be adequately stored and protected


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from theft/breach until all stored media/data are rendered inoperable and unreadable.

2. All equipment with potential re‐use capacity shall be fully tested, ensuring that all the information contained on these are completely deleted and destroyed. Such equipment should be in a good state of repair or functional whenever marketed or re‐distributed as refurbished products/items.

3. Products that are non‐functional shall not be re‐marketed or re‐distributed as refurbished for re‐use and should be treated either domestically or internationally for which it can be recycled or disposed of in an environmentally friendly manner.

4. Business owner(s) shall be responsible for ensuring the final Data Destruction was successfully

completed. A certificate of Data Destruction shall be provided by the respective vendor to ensure all data, existing operating system software, information or formatting was irretrievably destroyed following the approved methods.

6. Waste Management Hierarchy for Hazardous Substances and E‐waste Handling

Hazardous waste management practices dictate that waste is to be processed in the most environmentally friendly way. If handled improperly, toxic components found in E‐waste or as a hazardous substance can find their way into water or air and potentially cause serious illnesses or diseases in animals and/or humans. Therefore the hierarchy of control below will provide a user a guide on the various options that must be considered prior to final landfill disposals.

6.1. The hierarchy of Control for Hazardous Substances/E‐waste

The following is mandatory with regards to the Control for Hazardous Substances/E‐waste.

1. The re‐use of all electronics equipment, components or re‐manufactured items/substances if in

good condition.

2. Recycling equipment or components/substances for material recovery such as: metals, plastics, oils, batteries etc.


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3. Disposal of components via incineration or landfill. This method shall be only considered when items are confidential or require final destruction. Lastly, items which are completely damaged and cannot be recovered for any use.

Hazardous Substances In terms of Hazardous Substances the following requirements are mandatory ensuring safe disposal procedures are enforced. 1. Determine the characteristics of the substances to classify it as hazardous. This will depend on the

following requirements which can be obtained from the manufacturer’s specification or material safety data sheets.

Ignitability: Liquids with a flash point of 60 °C (140 °F) or below, oxidizers or spontaneously combustible materials.

Corrosivity: pH ≤ 2 or ≥ 12.5.

Reactivity: Materials that readily explode or undergo violent reactions (D‐Codes).

Toxicity: Wastes likely to leach dangerous concentrations of toxic chemicals into ground water.

2. It is the business owner(s) responsibility to ensure such substances are highlighted/brought up

during the disposal approval process and specifically notified to Procurement, ensuring the appropriate vendor is selected to manage and control such substances.

6.1.1. The following procedures are mandatory when Handling/Disposing of Hazardous Substances

1. All hazardous waste substances must be stored in sealed containers and chemicals must be

compatible with the containers material (e.g. acids must not be placed in a metal container).

2. Chemical waste must be segregated by general waste type (e.g. flammables, poisons, acids and alkalis) and arranged so that incompatible substances do not mix.

3. Below are a few general principles which must be followed for safe hazardous waste/chemical storage:


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Store acids and bases separately

Keep acids apart from cyanides or sulphides

Acids should never be put into steel containers

Water‐reactive and strong acids such as organic acid halides, organic acid anhydrides, inorganic acid anhydrides and strong acidic salts must be kept apart from both alkalis and water

Oxidizing agents must be kept apart from reducing agents and organic compounds

Water‐reactive agents must be stored apart from water, aqueous solutions and acids

Air‐reactive materials must be packed in containers that are sealed off from the atmosphere

Explosive and shock‐sensitive materials present risks that require special handling

1. When hazardous substances have been defined as reusable or may be recycled, the user must then send a request through Supply Chain shall source an approved accredited supplier to collect, and transport such wastes for its specific treatment. Appropriate recycling/reusing certificates must be issued by the supplier.

2. When hazardous substances cannot be re‐used or recycled, the user must then send a request via Supply Chain for the final disposal of such substances. Supply Chain shall source an accredited approved supplier for the removal of such hazardous waste.

3. Upon selection of the approved supplier, the required municipality regulations must be applied

for final disposal. These methods shall be determined by the local authority and through recommendations made by the approved supplier.

4. Any containers holding hazardous chemical substances or waste shall be kept securely closed, so there is no leakage or escape of vapors during its storage, except when it is necessary to add or remove chemicals/waste.

5. All containers must be clearly identified and labeled with the proper chemical name(s) of the substance(s). The applicable material data sheet must be available and accompanied with the relevant hazardous substance.


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6.1.2. The following procedures are mandatory when Handling Electronic Wastes for Disposal

The relevant parties must follow the principle of reduce, re‐use and recycle for management of electronic waste. Electronic waste items are to be segregated into 2 categories:

1. Items which can be re‐used 2. Item which are to be destroyed by way of proper recycling or final destruction

It is the business owner(s) responsibility via the disposal Form (Finance form) to state whether items are in a good state of repair and can be re‐used.

6.2. The following Re‐used Options are to be considered

1. Returned back to the Manufacturer or Service Provider: It shall be a priority to return all used products where applicable back to the manufacturer. This will be dependant if the manufacturer or service provider(s) have a return policy. It shall be the business owner(s) responsibility via Supply Chain to enquire on return policies within existing vendors.

6.2.1. Selling to third parties

Selling any items whether E‐waste or hazardous wastes shall follow the below requirements: 1. The vendor must demonstrate environmental compliance by having certifications in ISO 14001 or

other international best practice environmental guidelines

2. Based on the request of service/scope the required vendor is to demonstrate the procedures for removal, destruction and recycling of the waste

3. Where items are sold by the vendor, the environmental burden lies solely with the supplier.


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4. The respective vendor is to ensure that all data is erased and completely destroyed prior to re‐sale and recycling processes where applicable

5. It is mandatory to provide du with destruction and recycling certificates by the respective vendor/supplier where applicable

6. All UAE compliance regulations shall be adhered to where applicable. International trans boundary requirements shall be adhered to when items are shipped to other destinations (WEEE directives, Basel Conventions or other requirements as deemed necessary)

7. It is recommended as far as possible that all hazardous substance be recycled and if not be disposed off locally following all UAE regulations

Items in good working order 1. Where items are in a good state of repair, then suitable suppliers shall be sourced via the Supply

Chain process for the resale or re‐use of items.

2. Suppliers are to complete the Vendor HSE Compliance Form as a prerequisite.

3. They must then be registered as re‐used items within the distributed market and a statistical breakdown shall be kept by the user and Supply Chain

Items requiring re‐furbishing/dismantling prior to re‐sale

1. Items that are damaged and require refurbishment may also be sold to third party suppliers;

although the above requirements shall still be adhered to

2. The supplier is to accept full responsibility based on the condition of items being sold

3. It is du’s responsibility to inform the supplier of the condition of the equipment and if there are any hazardous components that require special precautions

4. Where items are entirely dismantled and segregated, then the supplier is to provide du with an HSE plan as follows:

Which items will be recovered and the purpose of recovery


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Items that are hazardous shall be controlled and disposed of safely (permits and destruction certificates will apply for hazardous components disposal)

Items that cannot be recovered shall be disposed off in a safe environmental manner

Statistical breakdown of items shall be provided by the supplier to du for record purposes

6.2.2. Sold/Donated to Internal Staff

1. Items that are in a good state of repair/condition and shall only be considered for internal staff sale or donation

2. Items that contain hazardous substances and will directly affect health of individuals will not be sold or donated to staff

3. A list of items shall be kept for record purposes by the user and Finance as to items donated/sold internally

Donated to Organizations (NGO’s, institutions etc)

1. Donations to organizations shall be considered as part of our Corporate Social Responsibility

Policy.

2. Items that contain hazardous substances and will directly affect the health of others will not be donated to institutions that have children, elderly or to education or health care institutions. Such items will only be considered, unless there are specific programs in place within such organizations and must be approved by the HSSE department and CSR prior to donation

3. Donating non‐hazardous, functioning technology to registered charitable organizations, non‐profit organizations and trusts should be considered on a case‐by‐case basis and must adhere to the manufacturer’s end‐user license agreements and applicable copyright laws.

4. A list of items donated to third parties shall be kept by CSR.

6.3. The following recycle options are to be considered


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Where refurbishment or re‐sale is not an option, every reasonable effort will be made to control all hazardous and or electronic waste from entering landfills, incinerators or entering any anti‐environmental process. Hence recycling of all elements shall be considered where reasonably possible.

6.3.1. Items Sold to Third Parties

Such items will follow our Supply Chain Policy where a suitable supplier shall bid for the purchasing or removal of such items. Here the supplier shall ensure that items are locally recycled where possible (within the UAE) before considerations for trans boundary export. The applicable supplier shall provide the following requirements to du as part of its Environmental Compliance:

Complete the HSE vendor Compliance forms

Provide an HSE plan in accordance to the recycling of the item(s)

Provide detailed recycling certificates that quantify the waste into categories and quantities recycled

Comply with all UAE requirements and international certifications for transportation and environmentally friendly recycling procedures

The above requirements shall be communicated to the relevant requestor and or HSSE department for its verification and final technical approvals.

6.4. The following Destruction and Final Disposal Requirements are to be

considered

The final destruction of items shall be determined through the approval cycle and the Finance Asset right off policy document. This will be determined by the respective business owner(s) as to the following requirements:

Confidential items may require physical destruction

Hazardous material/substances that would require final disposal/destruction


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Items that are not re‐usable and or damaged and require final destruction and disposal

6.4.1. The Physical destruction shall encompass the following requirements:

The physical destruction and disposal of unusable hazardous or E‐waste technology should be undertaken by certified or licensed E‐waste professionals. Data Destruction Data Destruction shall take on the forms as follows:

1. Shredding of material/components of material. 2. Using approved software systems that erase data from equipment. 3. Restoring equipment back to its default settings.

6.4.2. The final disposal practices shall encompass the following requirements:

All materials that cannot be re‐used or recovered in any way shall be considered for final disposal. This means that the items shall either be landfilled in designated areas or incinerated under defined processes by authority having jurisdiction. Where possible landfilling shall be avoided as this may increase the leaching effects on the environment. Equipment containing hazardous and regulated materials shall not be landfilled. These include, but are not limited to:

‐ Whole monitors, CPUs, televisions and printers ‐ Printed circuit boards containing lead, mercury lamps and switches ‐ Cathode ray tubes (CRT) and CRT glass ‐ Batteries ‐ LCDs and plasma screens ‐ Any materials containing lead, mercury, cadmium, hexavalent chromium or PCBs

Required documentation is to be provided by the supplier for safe disposal in regulated landfills or its incineration.

7. Third Party Selection and Approval Requirements


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All du vendors who provide disposal services, including but not limited to the initial step of sorting equipment for testing, re‐use, re‐furbishing, repair, recycling or disposal shall ensure that all environmental compliances listed below are met prior to the disposal of such items.

1. Provide du with all applicable certificates for the collection, removal, transport and final disposal (permits)

2. Provide a health and safety plan to illustrate the safety precautions taken to reduce environmental impact.

3. Provide a detailed environmental plan illustrating how items will be disposed of, by reducing environmental impact.

4. Provide specific certifications relevant to environmental compliance such as (ISO 14001 or other best practice qualifications)

5. Provide final recycle certificates for items/or components of items that have been recycled. Such recycle certificates shall have the weightage and category of the products recycled.

6. Have completed the du HSE contractor Assessment forms.

7. All exports of wastes must comply with existing international waste trade agreements and legal requirements of the UAE.

Where the above requirements cannot be attained, then required approvals from the HSSE department shall be obtained to continue with selected vendors.

8. Financial Gains on Waste Items: The business owner(s) in conjunction with Supply Chain shall ensure the best commercial requirements are achieved for the removal and disposal of any items. Where disposal costs shall be incurred, then this shall be the responsibility of the business owner(s). Applicable costs must be illustrated where required during the Asset disposal write off process. The disposal costs shall be justifiable and shall not exceed the depreciated value of the item. Where there is a financial benefit for du during the re‐use/recycling phases, then this must be approved by du’s Financial department’s terms and conditions.


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9. Reviewing the Policy

This Policy will be reviewed regularly based on its effective implementation. It will be updated as and when business needs change. It will be reviewed as per the document control procedures within the HSE management System.

10. Definitions, abbreviation and acronyms

Definition, Abbreviation or Acronym

Explanation

HSE Health, Safety and Environmental

OHSAS Occupational Health Safety Assessment Series

ISO International Standards Organization

UAE United Arab Emirates

LEED Leadership in Energy and Environmental Design

EPEAT Electronic Product Environmental Assessment Tool

CSR Corporate Social Responsibility

WEEE Waste Electronic and Electrical Equipment

Energy efficient Products or facilities that use less energy than typical products or facilities to provide a given energy service (heating, lighting etc) or level of activity.

E‐Wastes: Electronic waste, E‐waste, E‐scrap, or Waste Electrical and Electronic Equipment (WEEE) describes loosely discarded, surplus, obsolete or broken electrical or electronic devices.

Environmentally Friendly

Environmentally friendly means that none of the waste will be handled in such a way as to contaminate/harm the environment.

Hazardous wastes Means an inorganic or organic element/compound that, because of its toxicological, physical, chemical or persistency properties, may exercise detrimental, acute or chronic impacts


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on human health and the environment.

This can be generated from a variety of activities and may take the form of liquid, sludge, gas or solid. Hazardous materials can also be defined to be any substance that directly or indirectly represents a threat to human health or to the environment by introducing one or more of the following risks:

- Explosion or fire - Infections, pathogens, parasites or their vectors - Chemical instability, reactions or corrosion - Acute or chronic toxicity - Cancer, mutations or birth defects - Toxicity or damage to the ecosystem or natural resources accumulation in biological food chains, persistence in the environment or multiple adverse effects.

Re‐use Re‐use extends the useful life of an asset, maximizing its overall value and delaying the consumption of raw materials and energy to produce new assets.

Recycle Recycling is processing used materials (waste) into new products to prevent waste of potentially useful materials, reduce the consumption of fresh raw materials, reduce energy usage, reduce air pollution (from incineration) and water pollution (from land filling) by reducing the need for ‘conventional’ waste disposal and lower greenhouse gas emissions as compared to virgin production.

Waste Disposal Waste disposal includes the collection, transport, storage, sorting and treatment needed to recover the reusable components and materials or energy and the filing or release into the environment of all other products in conditions that prevent nuisances mentioned in the preceding paragraph.

Final disposal and destruction

Disposal is defined as any waste management operation serving or carrying out the final treatment and disposal of waste. It covers the following main operations:

Final treatment:

- Incineration without energy recovery (on land; at sea) - Biological, physical, chemical treatment resulting in products


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or residues that are discarded, i.e. going to final disposal

Final disposal:

- Deposit into or onto land (e.g. landfill), including specially engineered landfill - Deep injection - Surface impoundment - Release into water bodies - Permanent storage

Practicable Means that a product or service is satisfactory in performance and is available at a reasonable cost.

Natural resources Or virgin materials are naturally occurring substances that are considered valuable in their unmodified form for example forestry, fishing, or mining. These previously unused raw materials can be extracted from the earth by mechanical processes.

Renewable resources A natural resource qualifies as a renewable resource if its stock (quantity) can increase over time and not decrease, for example oxygen, fresh water, solar and wind energy, timber and biomass.

Recycled materials Are those that have been reprocessed from recovered (reclaimed) material by means of a manufacturing process and made into a final product or into a component for incorporation into a product?

Waste The European Union defines waste as an object the holder discards, intends to discard or is required to discard is waste under the Waste Framework Directive (European Directive 75/442/EC as amended).

Any person who produces or holds waste, in conditions likely to produce harmful effects on soil, flora and fauna, to degrade the sites or landscapes, pollute the air or water, generate noise and smells and generally affect human health and environment, is obliged to provide or to ensure the elimination in accordance with the provisions of this act in conditions to avoid those effects.


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Re‐manufacture Means to renew or restore a used product into its original form or into a useful new product through a commercial process.

Cradle to Grave means the duty to ensure that a product or service, from its conception to its demise, is handled in an environmentally friendly and accountable manner

Duty of Care means that any enterprise or subsidiary has a duty to utilize the environment responsibly for sustainability of consumption and production

HSE Health, Safety and Environmental

OHSAS Occupational Health Safety Assessment Series

11. References

1. Federal Law No. (24) Of 1999 for the PROTECTION AND DEVELOPMENT OF THE ENVIRONMENT 2. Requirements and Procedures for the Disposal of Hazardous Wastes, Technical Guideline Number 26

Documents

Hazardous Waste Management Policy. - du