Policy recommendation report to EEAA on

An Integrated Waste Management System

for mercury containing Hazardous Waste

Dec. 2009

KOICA and ENVICO

Chapter1. Introduction

1.1 Background

Management of solid waste in Egypt is very poor. In the greater Cairo region, waste collection

is made by private companies in contracts with Governorates. Governorates collect waste fees from

the residents, invoiced with electricity bill and repay the companies. The revenue from waste fees is

not enough for the payment to the companies. Many residents do not pay the fees. Governorates run

deficit in the waste account and the private companies do not collect waste. Waste are dumped in all

over the regions and left uncollected.

The poor management of municipal solid waste casts a severe problem with the hazardous

waste such as FLW. Hazardous wastes are not separated and collected together with other non

hazardous wastes or simply dumped on the roads and streets uncollected. Most of the FLW are

broken and the mercury contained in the lamps is emitted untreated into the air. The worst thing is

that people do not understand its risk to health. Not only public but also officials in charge of waste at

the central government as well as local authorities do not recognize the significance of the danger.

Another problem comes from the FL manufacturers. The factories produce large volume of

defected FLs due to poor quality control. Average rate of defected goods out of total products reaches

to %. All the defected goods are reused at site without a proper treatment of the mercury. It is easily

imagined the site is heavily contaminated by mercury and workers are exposed to a very dangerous

working condition.

The EEAA has come to recognize this situation and to decide to solve this problem by

constructing a FL recycling facility. Egyptian government applied KOICA for an aid in this field and

KOICA decided to provide an aid for construction of a FL recycling facility with some professional

consultancy services regarding policy and administration matters required to guarantee the normal

operation of the factory under the name of the Project for the Management of Mercury Waste.

KOICA had dispatched an expert of waste policies to study the current status of mercury

waste management in Egypt, and to provide the government with consultancy on establishing an

efficient waste collection system of FLWs and on formulating policies & programs for supporting the

Mercury Waste Project. The policies and programs include;

a. general scheme of collection and treatment of FL wastes

b. organizations- and responsibility sharing among the stakeholders

c. financing and implementation strategies

d. draft for new legislation

e. revision of existing laws & acts related

This report is about the above consultancy services. It summarizes the current status of infra

structures and actual management of mercury containing waste to identify problems. It suggests

some solutions by recommending to establish an IWMS for FLWs with a list of infra structures,

facilities & equipments, manpower and legal as well as social systems to support the management

system. It also suggests a phase-wise implementation strategy considering the capacity of Egyptian

government. The primary goal of this consultancy report is to recommend EEAA to make policies for

the establishment of a stable supply system of the FL waste and a sustainable financing scheme for

the normal operation of the recycling facility to be constructed. It will introduce various alternative

policy tools for the establishment of the IWMS and suggest a most feasible scheme with a practical

implementation plan in consideration of the current socio-economic conditions and environment of the

country and government capacity.

1.2 Method and scope of research

The primary goal of this report is to find out a system for safe and economical management

system for FL wastes. For this goal, the report provides a review of the surveys conducted by joint

working group of Korean expert and EEAA personnel on current status of mercury waste

management. The surveys are preliminary survey on the general status of FL manufacturers and field

survey on sources, waste volumes, discharging practice, collection and treatment status of FL wastes.

The scope of hazardous waste is limited to mercury containing waste. They include industrial

waste from electrolysis process (NaOH, KOH), mercury using factories (thermometers, barometers,

rectifier, catalysts etc.). The mercury substances generated in the form of air pollutants emitted from

the factories with processes of metallurgy, iron-metal alloy, cement, glass, waste incineration are

excluded. The primary focus will be given on the FL wastes and sometimes on waste thermometers of

which the waste volume is large enough to cast environmental problems. Other mercury containing

wastes discharged in a small quantity are considered only when laws and acts concerning hazardous

waste are related. The legal systems and policy programs cover all the jurisdictions of the nation, but

for collection and financing plans for the project, the geographical regions may be restricted to greater

Cairo regions or some regions near Alexandria Governorate.

1.3 Activities undertaken by the expert

The waste policy expert has been dispatched three times to the field to have a site study, to

interview various stakeholders & government officials and to collect documents and materials. The

expert had a regular meeting with the government officials in charge of this project and Korean PMs

and KOICA personnel. The expert has had several site tours of the source areas and planned facility

site.

The expert has guided the survey team by providing survey team with questionnaires and

guidelines instructing regions and targets to be surveyed. The whole process of survey has been

reviewed by the expert and the result & statistics has been analyzed to identify problems on issue,

measuring their significances to assign priorities. The urgent problems to be tackled by this project

and other problems to be considered in later time are classified and decided.

A review work has been conducted on laws and acts concerning hazardous waste

management together with government policies and programs including government budgets. The

expert made a master plan for the FLW problems. The plan classified the scope of waste generating

sources into four groups each of which will be tackled by a different phase strategy under different

implementation plan. The plan proposes a policy suggestion for establishing an efficient and stable

supply system of the FL wastes and a stable financing scheme. The plan suggests

a. general idea of IWMS to be implemented over a long time period

b. an efficient collection scheme for this project (the quantity of FL wastes enough for the

normal operation of the facility to be constructed by this project)

c. list of facilities and other infra structures required for the implementation of each phase

of the IWMS plan

d. estimation of the investment and operational cost of the projects to be undertaken by the

IWMS plan

e. some policy suggestion for the financing of the estimated cost together with other

supplementary policy measures

This report has been submitted to the Egyptian government for the review and revised

through a serious of joint works of the expert and Egyptian government officials for more feasible

solutions and detailed action plans.

Following chapter wiil be completed after the survey

Chapter2. Review of current systems and status of waste management

2.1 General situation: An overview

Since 1992 many efforts have been made to cope with the aggravating municipal waste

problems through establishing national strategy for the waste management and making master plans

for the implementation. In spite of all these efforts in the government as well as local governorates

levels, the harmful manifestation of the waste problem is still showing its manifesting trend. The

accumulated waste volume is in an increasing state and complain is reaching its peak. The authorities

concerned are spending its scarce resources just for cleaning job of the places where the voice is

high. Though experts and government officials in charge keep on insisting to introduce an Integrated

Solid Waste Management System, there does not seem to be any movement toward to this. All

government organizations are pre-occupied by the current issues of cleaning the worst regions just to

mitigate complains.

Evidently the government does not have any capacity room to spare for the management of

the municipal hazardous waste discharged with other municipal wastes. Egypt has legal frameworks

and systems for hazardous waste generated from the industrial sectors. But the municipal hazardous

waste such as FL wastes or thermometers, mercury battery cells, and other mercury containing

wastes are left never been controlled. The public awareness on the risk and harmful effects of

mercury contained waste is so low that no one attempts to have some measure for the appropriate

management of the waste. The worst case is observed at the fluorescent lamps manufacturing

factories. They produce a lot of defected goods and all these defected goods are reused at the site

without appropriate treatment of the mercury substances contained in the defected fluorescent lamps.

No regulation for this reusing process is enforced. Workers are exposed to daily contamination of the

mercury substance. Residents are also exposed to the same dangers without knowing.

2.2 Legal frameworks

1) legal status of mercury containing waste

FLW and other mercury containing municipal waste are not classified as hazardous waste

though mercury substance is classified as hazardous material. The FL wastes and other mercury

containing municipal waste are regarded as general municipal waste and collected and disposed

together with other municipal waste. There is no special regulation on its collection and disposal.

2) Organization in charge of Hazardous Municipal Wastes

Local Authorities (Governorates and districts. The Cairo Cleaning and Beautification Agency -

CCBA has been established recently) are responsible for cleansing of the assigned regions and

collect and dispose the municipal waste discharge in their jurisdictions. Many of the Local Authorities

have contracts with private service companies on the waste collection and disposal. The service cost

is paid out of the cleansing fund which is financed from the revenue of waste fees from the residents.

The waste fees are decided at 2% of rental value of household and commercial activities and issued

with the electricity bill. The problem is that many households do not pay the bill in time and

governorates are always in the short of fund resulting in delayed payment or even no payment to the

contract companies. The private companies just leave waste uncollected for the regions where the

payment is not made. The governorates do not have any financial sources to be spared to special

collection of treatment of the hazardous municipal waste.

3) Rules and standards for collection and disposal of the waste

list of related laws. plans, programs

law no 38(1967)

31(19700 129(1982) No.4(1994)

clauses about hazardous waste

general acts on solid wastes

responsibilities of generators/ LAs/ government(MOE, EEAA)

rules and guidelines to be complied by collectors/treaters (will be filled later)

2.3 Waste management policies and programs

1) The National Strategy and Action Plan (1992)

2) The National Strategy for Integrated Municipal Solid Waste Management (2000)

- A Framework for Action:

This plan has been reported and suggested but does not seem to be implemented. The

report recognizes the negative manifestation of the aggravating waste problems to suggest

an integrated management system for the municipal waste with gradual transition strategy

for the implementation of the action plan. This research does not cover the hazardous waste

contained in the municipal waste.

3) Capacity of governorates

all waste collection and disposal is in charge of governorates

budget is not enough

total municipalities budget for public cleansing are so meager that far short of needs.

Cairo LE 29 mil

Alexandria LE 21 mil

total annual expenditure on SWM 110-126mil LE

Financing sources available (will be filled later)

2.4 Infra structures

1) discharging practice

FL wastes are not discharged in separate from other non-hazardous municipal waste. It is

hard to find FL wastes unbroken, most of them are broken and discharged comingled with other

municipal waste. No discharging boxes or containers are available. Wastes are simply dumped to

streets and other empty spaces. People litter their waste out of houses, buses and cars without any

recognition. No regulation is made for these free littering. All of the regions of cities are occupied by

waste.

2) collection system

It is rarely observed private companies collect waste. Animal pulled carts collect recyclable

waste such as cans, papers, glasses, plastics. Waste towns called "Zaballeen" are formed near the

old Cairo districts to collect waste and separate recyclable waste to sell. People live together with

waste and make living out of the waste. They have trucks for transportation and most of the

separation work is done by hands. Their living condition is very poor and other people do not like them

near their residence even though they play a very important role of cleaning the cities. Cities are

maintaining some cleanness thank to these people. Nonetheless, they are not paid for their roles. The

government is planning to move them out of the city to the desert area. FL wastes and other

hazardous waste are not collected or separated by these people, either.

3) LAs capacity

Though Local Authorities have equipments, manpower for cleaning and collection of the

municipal waste, not enough for managing all the waste, budget is so meager that it is used for

cleaning severely accumulated regions occasionally. No capacity or budget for hazardous waste at

all.

4) Survey of the private collection companies

equipments, manpower:

transfer stations

treatment facilities

disposal facilities: landfill, incineration, others

Private recycling/treatment companies

2.5 FLW management status: summary of survey

1) Sources and volumes

Industries

manufacturers of FLs

factories(thermometers)

Public sectors and building

universities,

schools

research institutes,

hospitals

Commercial sector

Buildings

Others

Residential areas

Cities/apartments

Rural areas

* estimation of accumulated quantity

2) discharge practice

Industries

Buildings

Houses

- revision of waste laws and acts are required to

enforce discharging duty of generators: sorting and put into boxes

* awareness of public/ LA officials/ governement officials/policy makers

3) collection

by local authorities (see diagram 1)

by private collectors

others

* barriers to efficient collection regulations

4) treatment/disposal

recycling at site

private recycling

Zaballeen

open dumping

others

restrictions/regulations/monitoring/penalties

by other laws and policies(water reserve/protection)

2.6 Problems

1) short of capacities

facilities

equipments

manpower

budget

other financial sources

2) Lack of separated collection system

3) low awareness

4) inappropriate organizational arrangement

responsibility sharing between central and local governments

between government and private(residents)

generators and government

Diagram 1. Organization in charge of waste, in case of Mansoura city

Chapter 3. Integrated Management System for hazardous municipal waste

3.1 Basic principle

1) Why an integrated system?

An Integrated Solid Waste Management system is for coordinating various waste activities in

one framework of management system understanding the inter-relationship among various activities

making component activities complement one another. The UNEP international Environmental

Technology Center(1996) describes the importance of viewing solid waste management from an

integrated approach:

- Some problem can be solved more easily in combination with aspects of the waste

system than individually

- Adjustment to one area of the waste system can disrupt existing practice in other areas,

unless the changes are made in a coordinated manner

- Integration allows for capacity or resources to be completely used: economics of scale

for equipment or management infrastructure can often only be achieved when all of the

waste in a region is managed as part of a single system

- Public, private and informal sectors can be included in the waste management plan;

- An ISWM plan helps identify and select low cost alternatives: Some waste activities

cannot handle any charge, some will always be net expenses, while others may show a

profit. Without an ISWM plan, some revenue-producing activities are "skimmed off" and

treated as profitable, while activities related to maintenance of public health and safety

do not receive adequate funding and are managed insufficiently

The IWMS usually have clear and agreed hierarchy among various waste activities and

alternative management strategies. This hierarchy established helps to identify key elements of an

ISWM plan. The general waste hierarchy accepted by industrialized countries is comprised of the

following order.

- Reduce

- Reuse

- Recycle

- Recover by waste transformation through physical, biological, or chemical

processing(e.g. composting, incineration …)

- Landfill

The institutional frameworks are made of tools used to implement the general waste policies

and the institutional roles and responsibilities include the following; (i) policy/planning; (ii)

licensing/permitting; (iii) operations; (iv) monitoring; (v) enforcement; (vi) education; (vii) financing/cost

recovery and (viii) administration. Clear delineation of these roles and responsibilities is essential to

the successful implementation of the system. The IWMS rearranges all the policies and programs for

the sub-goals of source reduction, reuse, efficient collection, recycling, thermal recovery and disposal

by landfill or incineration for the best achievement of the goals by avoiding conflicts among different

policies, by choosing policy tools in harmony with other tools with a clear allocation of responsibilities

as well as cost sharing among different stakeholders: generators (consumers, residents, users),

producers, governments. It also re-organizes the various and uncontrolled collection and disposal

activities by different agents in a unified system to enhance its efficiency.

2) Basic principles in establishing an integrated system

The waste problem of Egypt seems to stem from the lack of or poor capacity of waste

management. There are no facilities for appropriate treatment of the hazardous waste and no infra

structures for efficient collection of hazardous waste separated from the nonhazardous waste. No

governorates have an organization or personnel for the collection of hazardous waste. No budget is

available.

The more basic cause is with the low awareness about significance of the risk of mercury

contamination by the non-industrial mercury contained waste. People are even ignorant of the fact

that some wastes contain mercury substances. So the first emphasis of policies should be put on how

to upgrade the awareness of the risk of mercury waste for public as well as policy making levels.

One of the effective ways to enhance awareness is let the people pay the cost. In general,

people are ignorant about public issues especially when it does not require economic gain or loss.

People are so keen to economic interest that when they are required to pay something, then they

become sensitive and pay attention to the public issues. Making people who are responsible for

environmental contamination pay the monetary cost of the contamination is based on the Polluter Pay

Principle (PPP). This principle is to internalize external cost of environmental contamination. People,

by consuming goods containing hazardous substance and discarding the goods after

consumption(use), unknowingly, generate hazardous waste resulting in external environmental cost to

other non-users. The PPP asks the polluter(hazardous waste generators) to pay the environmental

cost by the hazardous waste they discharge. So the consumers of hazardous goods must pay the

cost for collection and safe disposal of the hazardous waste. Being enforced to pay this cost, people

become well aware of the risks of hazardous waste and its external cost. This also make people

pursue means of reducing the harmful result either by refraining from over consumption of the good or

complying with the discharging practice in the process of searching for reducing their financial burden.

The poor management of waste also comes from the inefficiency of government

bureaucracy. The highly complicated rules and procedures for administrative routines and the

bureaucratic attitudes of government officials trying to comply with the rules and formats rather than

pursuing rationality in their daily jobs cause a chronicle inefficiency of waste management mainly by

public sector. The myopic views of policy makers worsen the situation by delaying the establishment

of legal and other policy arrangements for the introduction of an efficient integrated waste

management system. In order to break this long lived inefficiency in the government sector, an

aggressive participation of private participation is inevitable.

So the Integrated System suggested here for the proper management of hazardous

municipal waste should be formulated on the two basic pillars of PPP and Commercialization

principle. First, government must establish PPP in waste management. Clear identification of

polluters, agents responsible for the generation of waste should be made by legal arrangement. For

the hazardous waste, the dischargers who had used the goods becoming waste are primary polluters.

In the case of mercury containing waste, consumers of the FLs and other mercury containing goods

are the agents responsible for the waste. For defected FLs, manufacturers are responsible for the

waste management. So these agents should pay all the cost for collection and treatment. Local

authorities often share the responsibilities with consumers, since local authorities responsible for the

waste in their jurisdictions. Local authorities can collect and treat the waste and the cost paid by local

authorities is born by consumers with increased tax burden or goods price. Roles and responsibilities

may be allocated among the agents different from the polluting responsibilities for the efficient

management.

stakeholders roles/responsibilities cost payment

Consumers(users)

householdspublic sectors

dischargeall the costpaying the taxpaying price

commercial self collection and treatmentall the cost paying the collectors and treaters

Producers(manufacturers)

defected goods

self collection and treatment all the cost

used goods EPR responsibilityshare cost with consumers and governments

Local authorities collection and treatment

pay the private companies in contractcollect waste fees from residents

Central governmentestablish infra-structuresubsidies to local authorities

out of general tax orspecial waste tax

It is desirable all the activities for physical collection and treatment of the waste be

undertaken by private business on the commercial profit basis. Private companies are keen to profits

and to costs and will find most efficient ways in all the stages of waste management, collection,

transportation, treatment, and final disposal. Government should make the environment for maximum

participation of private enterprise in the waste management business. Various projects and programs

should be introduced to induce the private investment from domestic as well as foreign sources.

Government should provide a clear set of rules for the business. Private funds must be induced with a

firm guarantee for the recovery of investment funds which can be made by contracts between

governments and private companies on the ways of collecting fees and subsidies in the case of not

reaching the proposed level of revenue. Private operators of the treatment facilities or transporters of

the waste should be guaranteed with fees enough for the actual cost. For these contracts,

government should establish standard contract formats and procedures. Government also shows a

stable and sustainable business environment with long term master plans for waste policies.

And the government must confine its roles to formulation and enforcement of the standards

and rules to be complied in the whole procedures of collection, transportation and treatment of

hazardous waste and monitoring and supervision of the activities. Government should implement

various programs to upgrade public awareness and conduct survey and statistics-related projects.

And Local governorates should be given monitoring and supervision responsibilities for the activities

taken in their jurisdiction, and some limited work of collection.

3.2 prerequisite

1) establishing an IWMS for municipal waste

Here FLW and other mercury containing waste are the hazardous waste from municipal

waste(municipal hazardous waste) and are discharged and collected in the same region and usually

in the same practice as the non-hazardous waste. The management system of the municipal

hazardous waste, therefore, should be established under the umbrella of the management system of

the all the municipal waste, and in harmony with the other municipal waste management. This means

there must be an integrated management system for the all the municipal waste established, before

an integrated municipal hazardous waste management system can be established. If the municipal

waste is not managed systematically in an integrated approach, the municipal hazardous waste

cannot be effectively managed, even though we introduce an integrated management system for the

hazardous waste. So a rough sketch of an integrated waste management system for the general

municipal waste is provided, here.

An integrated approach to the management of municipal wastes requires a set of alternative

management strategies toward a minimization goal; minimization of waste volume and minimization of

the waste cost. Alternative management strategies include various collection system and

disposal/treatment methods and an appropriate combination of collection and treatment method is

chosen for a certain waste from a certain source. So an integrated waste management system is

composed of different sets of discharging, collection, transportation, recycling and other disposal

methods for different kinds of wastes. The chosen approach of management strategy for certain

waste must be the best one available, in terms of effectiveness and efficiency. For this purpose, there

must a hierarchy clearly agreed upon among the members of the society, in choosing an approach

out of alternative collection and treatment methods for a certain waste.

The hierarchy is for the best fulfillment of the goal of minimization. The hierarchy agreed in

most societies are; first reduction at source, secondly, reuse, thirdly recycling(material first and then

thermal) and finally safe and sanitary disposal either by incineration or landfill. The integrated

management system suggested to be suitable for Egyptian situation and environment, therefore, must

have the same hierarchy; reduction, reuse, recycling and sanitary disposal. The municipal waste are

classified into several groups; Food and organic(garden) waste, packaging waste, e-waste, hazardous

waste, other residual garbage. For different groups different strategies should be chosen in

satisfaction of the hierarchy principle for the best achievement of minimization goal.

The integrated management also includes integration of all efforts of all the members of the

society. Roles and responsibility are allocated and shared among all the stakeholders for the

maximum participation and effective and efficient role playing of each member. A basic principle for

drawing maximum participation is the PPP. An appropriate responsibility sharing is made by an

agreed upon cost sharing based on this Polluters Pay principle. Now most countries are shifting the

responsibility for municipal waste from sole responsibility of local governments to shared responsibility

system among consumers(dischargers, generators), producers and governments(Local and central).

This shift increases the awareness of the public other than local authorities about the significance of

waste issues leading to more active participation of the waste reduction programs in pursuing the

saving of their financial burden. Producers are also become more concerned about waste of their

products, leading to various efforts to reduce waste volume and easy recycling of their waste. This

also increases the entry of private funds and enterprises in the waste business resulting in an

enhanced efficiency of waste management contributing to the waste cost minimization goal. Under the

integrated system, government role is confined to presetting of the rules and standards for the

appropriate treatment of the waste, legislation for the implementation of the rules, and enforcement of

the laws and acts, design of collection scheme for the best service to residents and least cost of

collection, arrangement of roles and responsibilities among all the members of the society, and

construction of the infrastructures. Consumers are assigned the general duties to reduce the waste

volume they generate in one way or another, comply with the discharging practice, and finally bear all

the burden of waste cost through tax increase or price increase. Producers are assigned duties to

refrain from excess packages, to develop environment friendly goods with design for environment,

material and structure improvement for easier recycling, redesign of logistic routes considering waste

collection and recovery, and share of waste cost. The role of producers is usually enforced by

implementing EPR system for packaging waste and e-waste and some hazardous waste. Consumers’

responsibilities are encouraged by some incentives such as volume rate waste fee system and

campaigns for upgrading their awareness. Followings are the roles of each stakeholder and some

policy measures for the maximum participation.

stakeholders responsibilities regulation incentives

consumers

reduce over consumptionprolonged useincreased reuse

volume rate of waste fee

consumption tax2nd hand market refurbished goods

separated discharge of recyclable waste

exemption of waste feerecycling centermileage and exchange program

producerschange of goods for easier recycling

Eco-assurance

active participation of recycling

EPR

local authorities

efficient collection schemefinancial burden for collection

financial and administrative assistance

monitor and supervision general responsibilityguidelinesjoint supervision

2) An IWMS for e-waste

Institutional frameworks for fluorescent lamp waste management are the same tools used to

implement e-waste management policy, since fluorescent lamps are electric/electronic products and

their producers are subject to same regulation for other electric and electronic industries. And before

introducing IWMS for fluorescent lamp waste, an efficient management system for all e-waste should

be established. So here is provided a rough idea of an integrated management system for e-waste.

Most e-wastes have some valuable materials and can easily be recycled with commercial

profits. With the soaring prices of low materials the so called urban mining is popular among

government officials as well as private business. The private business can instantly make profit out of

the e-waste recycling business, provided that enough quantity of waste are collected. And this

collection anticipated to be performed by governments, at least in the public sector, though actual

collection can be undertaken by commercial business. Government must establish an infra structure

for efficient and stable collection and supply of e-waste.

The infrastructures include legal framework controlling discharging practice and assigning

collection duties for certain economic agents, like free acceptance of collection of used e-goods, EPR,

consumer-deposit, exchange program by retailers, and operation of physical facilities for collection

such as collection centers, bring back centers, and various assistance programs for recycling

industries.

3.3 Establishing PPP and responsibility allocation

1) Different responsibility sharing for different kinds of waste

Before establishing integrated management system, mercury containing hazardous wastes

should be classified into two groups; defected goods from manufacturers and post-consumption

waste. The waste generator of the defected goods are manufacturers of fluorescent lamps and other

mercury containing goods and those of post-consumption waste are users of the goods. The users

are classified into two groups of big users and households. Big users are again composed of two

groups; commercial users for commercial buildings, factories, big retail shops, entertainment facilities

and other business sites and public or institutional users of hospitals, universities and schools,

research institutes, government buildings. All the users big or small, are all generators of hazardous

waste and must be responsible for their waste. In sharing responsibilities among stakeholders,

however, big commercial users should be treated different from the other users. Commercial users

are in the good position to transfer their financial burden to other economic agents of consumers or

their previous stage producers. In addition most of them have some control for the efficient collection

or treatment of their waste in choosing contract companies because of large bulk of the waste and

control of discharging practice, while households and small users do not enjoy such position. Public

and institutional users can be treated like commercial big users because they can enjoy the same

position but their activities are under the control of government so can be subject to government direct

control and can be treated differently.

2) responsibility for defected FLs

The responsibility for appropriate management of defected goods is assigned to

manufacturers of the goods. The producers should collect and treat their defected goods with their

own expenses according to the rules and standards in safe and with no impact on environment and

people. They can entrust professional commercial business with their job. The entrusted private

companies must have been licensed for their business with facilities and manpower required.

3) Responsibility for post consumption waste from commercial sectors

The owners of the buildings or business sites are responsible for the management of their

waste. They must collect and treat their waste with their own expenses, according to the rules and

standards, in safe and no impact on environment and people. They can entrust professional

commercial business with their job. The entrusted private companies must have licenses for their

business activities with facilities and manpower required.

4) Responsibility for the post consumption waste from public sectors

For these waste local authorities are responsible for collection and treatment. LAs must establish an

efficient and safe collection scheme and operate facilities. Of course LAs can entrust private

companies with the collection and/or treatment work. LAs pay the cost out of the budget or cleansing

fund made by waste fees from the residents.

5) Responsibility for the post consumption waste from households and residential areas

For these LAs are primarily responsible for the collection and treatment. But LAs can assign

additional responsibility for residents to comply with the discharging practice, with penalty in case of

non compliance. LAs can have campaign or events to collect rarely generated hazardous waste such

as Mercury cells, thermometers which provides LAs with enough volume of waste for a separate

treatment

3.4 Privatization and Commercial operation of facilities for collection and treatment

The second pillar supporting IWMS is an active participation of private fund and enterprises

in the collection and treatment business. There are two realistic constraints for inducing private funds

and enterprises into the waste business; (i) not enough incentives guaranteeing commercial profit and

stability of business environment and (ii) a supervisory system for business activities and practice

ensuring their compliance with all the regulations and so acceptance by public for their satisfaction.

Two arrangements are in need, for the overcome of these constraints; the first one is

provision of a stable and sustainable business environment and enough incentives for private

participation and second is establishment of a monitoring and supervision mechanism legally bounded

and equipped with effective enforcement measures.

Private fund and enterprises are very keen to profits and the business environment. If the

environment is not seen stable and so recovery of investment is not clearly foreseen, the private

participation would be hesitated. Most of all the attitude of government must be decisive and all policy

formulation and implementation must have long time horizon, much longer than private business

plans. Markets for environment industry are created and sustained by environmental regulation, so all

the environmental policies must have clear goals and missions to be pursued for a long time.

Otherwise the markets cannot show a sustainable development in the future. For all these

government show it's firm position by announcing a long term master plan. Measures for fair

competition among the private enterprises through strict licensing are also in need. Strictly enforced

and regular monitoring for ensuring appropriate collection and treatment will contributes to preventing

enterprises' easy entry and exit for short run profit destroying the market.

For the initial stage of the plan, government can initiate business activities by constructing

facilities and lease them to private operators. A continuous flow of cash should be secured for this

lease enough for financing the daily operation. As the profitably become visible government can

induce private funds which invests for the construction of facilities and recover the cost out of the

revenues from the operation of the facilities. Government can initiate private funds for the waste

business by introducing tax exemptions and other privileges.

3.5 Collection system: Dual system

1) a separated collection system from the general municipal waste collection.

As mentioned above, municipal waste is discharged according to separated discharging

practice into several categories. Food and organic waste are discharged into special food waste

containers and collected by composters. Recyclable waste are sorted into several kinds and

discharged into different bins; paper, cans, glass bottles, and are collected by recyclers. E-wastes are

collected by private recyclers/collectors or EPR producers(or entrusted recyclers or their joint

organization, PRO). FL wastes and other mercury containing waste should be discharged by users to

special containers designed for safe storage and transportation and placed in the designated area

near sources. Different sources have different modes of discharge and collection of the same waste.

2) Defected goods from manufacturers

Generators(FL manufacturers) should collect their waste in the safe boxes, the specification

will be made by EEAA and announced with other rules and guidelines. They transport the waste to the

facility with their own expenses. Facility operators or the entrusted transporters can transport on

contract. The transportation cost will be paid by manufacturers. Manufacturers also pay the treatment

cost. The standard cost will be announced by EEAA(appendix) Equipments for the transportation

must comply with the specifications and rules and guidelines to be announced by EEAA.

3) FL waste from big users

- Commercial sources

Users must keep collection boxes with government specification within their business sites

and transport them to facilities or make contract for the transportation. They must comply with the

collection methods and rules required by the transporters or facility operators in case of self

transportation

- Public sources

Users must keep collection boxes within their buildings and sites. Let the collectors collect

the boxes providing easy access and other convenience for collection workers. These collections are

made by local authorities or entrusted private collectors.

4) FL waste from small users

- Collection boxes

Local authorities must designate places for discharge and place boxes or other containers

which can be manage for preventing breaks and must have a monitoring system for appropriate

discharge and safe collection. Residents must comply with the local authorities’ rules and guidelines.

- Collection centers

Governorates can operate collection centers where those who bring the used lamps are

rewarded in various ways, cash, saving account, mileage, coupons for exchangeable with some

goods, even lottery. Some light penalty or fines can be replaced with the bring-back mileages. Private

companies also can operate collection centers where some incentives are given to those who bring

the waste. Operation cost can be subsidized by governments and/or by manufacturers. Retailers or

wholesalers can also operate collection centers sometimes with some consumer deposit system or an

exchange program which consumer can buy new one in exchange of old one. Automatic collection

using vending machine can be installed where people visit often such as parks, rest areas. The

machine rewards those who input FL wastes into the machine by giving coupons, or accumulating

mileage for future spending.

Diagram2. A schematic layout of collection system

5) Mercury cells, thermometers can be collected through events or campaign at schools

or other residents meetings

* rules and standards for collection and transportation and specifications of collection box :

appendices 1. will be provided by unit suppliers.

3.6 establishing a stable financing system

1) establishing PPP

Transferring responsibilities for municipal waste which have long been understood as one of

the basic services of LAs from government(tax payers) to generators(consumers and producers) is

visible throughout the world. This responsibility transferring is based on the PPP. The PPP providing

generators with incentives for reduction is a favorite menu of the policy makers in developed as well

as developing countries, since reduction is the primary sub-goal of the integrated waste management

systems. Korea, for an instance, has introduced the volume rate waste fee system which differentiates

the fees according to volume. The system is evaluated very successful in reducing overall waste

volume. Likewise PPP is necessary for the hazardous waste just to encourage efforts to reduce waste

volume. PPP can easily be applied to hazardous waste where the generators are clear.

For the successful implementation of the integrated hazardous waste management system,

PPP should be established in both general municipal waste and hazardous waste. The PPP realized

by differentiated waste fee scheme according to waste volume can contribute to separate discharge

or collection of hazardous waste when supplemented with no charge rule for the separated discharge

of certain waste such as recyclable waste, e-waste, and hazardous waste. The exemption of waste

fee gives people with incentives for separation of those wastes from the general waste to save waste

fee payment.

PPP in the hazardous waste is realized by making generators bear all the cost of collection,

transportation and treatment either by direct work or payment to the agents. All the cost are

determined by private contract basis depending on the terms and conditions but government can

provide a guideline for the decision of the fees. The generators, however, can have different scopes

depending on kinds and source. Manufacturers are generators for the defected goods. Big users are

generators for the waste from commercial sectors. Local authorities are regarded as generators for

the waste from public sectors and households on behalf of actual generators.

2) Alternative financing schemes for government cost

Government (or local authorities) must pay all the cost for the management of the FL wastes

except for defected goods and waste by big commercial users. This government payment can be

financed by various ways. Here are some examples.

A. Government financing

Investment funds for the construction of treatment facilities should be financed out of

government budget in principle. But in most cases developing country government do not have

enough budgets for the investment cost. Sometimes aid from international organizations or foreign

governments may be available, but these aids or grants are limited and mostly restricted to small pilot

facilities. Government needs stable financing sources other than foreign aids. Introducing an objective

tax or raising general tax rate can easily attempted but very often subjected to strong objections from

taxpayers and difficult to have congress consent.

As one of the means securing financial sources for government investment plans, invitation

programs for private funds are often recommended. If with enough budget, government can construct

the facility out of government budget and lease the facilities to private enterprises paying the

operation cost. These cases are not common with most developing countries. The more general type

of private fund invitation programs are let private funds invest their own money for the construction of

facility and give rights or issue licenses to operate the facility collecting service charges from users.

These rights are guaranteed until they can recover all the investment cost with some profit and in

case of loss(operation cost exceeds the fee revenue) government subsidize the loss. The participating

private funds are safe in doing business with exclusive operation rights sometimes monopoly power

without any competitors, and securing minimum profit in addition to recovery of investment money.

B. special waste charge

For the hazardous waste extra cost is required for their special collection and treatment

separated from general municipal waste, which are financed by waste fees and or local budgets. For

these extra costs, government levies product charges such as special waste charges. The special

waste charges can be levied to all mercury containing goods (fluorescent lamps, thermometers,

mercury battery cells ...) The revenue collected from this charge is used to finance the collection and

treatment work by local authorities being subsidized by central government or paying the directly

private operators and collectors.

C. Deposit-refund system

Producers must deposit money for the recycling cost of their product waste in advance. The

deposited money is refunded for the recycled quantity by producers. This system provides the

government enough financial source for the construction of infra structures and treatment of the waste

on behalf of producers.

D. EPR system

Producers are assigned recycling obligations of their product waste with mandated recycling

rate or quantity and penalized for the non compliance. Recycling charge is levied for the not-recycled

quantity. So the producers pay the recycling cost assisting the recycling business. The deposit-refund

system and EPR system should encourage producers to be engaged in product change efforts, such

as changed structures and materials of their products in favor of easy recycling. These strategy

changes are expected to be undertaken by enterprises in the process of pursuing for reducing

recycling cost.

Diagram 2. financing under EPR scheme

3.7 supplementary measures

1) Government inventory programs

There is needed an organization in charge of survey and statistics work. It should conduct

regular survey and establish and maintain a data base for status related statistics including list of

sources, generation volumes, collected volume, treated volume, and other statistics about industries

such as number of enterprises, sizes, capacity, performance, equipments, facilities, and manpower.

The organization can be a public agency or a private association of producers or recycling industries.

The organization must be supported by government budget and can be partly subsidized by

concerning producers and/or recycling industries.

2) Planning and implementation organization

There must be a government organization or government section in charge of managing the

system by formulating policies and programs, and implementation plans, set rules and standards and

undertake overall supervision of the enforcement organization, local authorities and obliged

producers. There also must be an organization in charge of enforcement. The organization accept

reports from producers and recyclers to check mis-maneuver, and confirm the quantity recycled with

confirming if the rules and procedures are complied in performing the collection and recycling jobs.

There must be a monitoring system for the reports of producers and waste generation and recycling

business.

3) Education and public campaign

Upgrading the public awareness about the risk to health and environment by the

inappropriate treatment of FL wastes is absolutely required for the maximum participation of public in

the management system. Strict compliance of discharging practice is critical to minimizing the

contamination risk from the leaks of Mercury into air and proper collection of waste, which greatly

contributes to reducing recycling cost. The upgrading program can effectively implemented by school

education programs and development of classes and education materials and supply of instructors

should be performed by government. Public campaign by central government through TV, media, ads

and commercials are also seen effective to draw peoples' attention to realize the significance and

events such as collection day of thermometers, batteries by local governments, or central government

and by residents meeting, or NGOs.

Chapter4. Design of EPR system

4.1 Concept and background

1) concept

EPR(Extended Producer Responsibility) is to transfer responsibilities for waste from local

authorities to producers, from tax payers to waste generators. The scope of producers' responsibility

is expanded from production of goods, sales and liability for the consumption period to the

management of their products after consumption. EPR places the responsibility upon the

manufactures to reduce the environmental impacts of their product at each stage of the products life

cycle- that is from the time the raw materials are extracted, produced and distributed through the end

use and disposal phases. Producers must collect and recycle the goods they sold after buyers discard

them. When consumers discard the goods they become waste tentatively but become raw materials

or new goods, so the waste to be recycled is defined as post consumption not waste. Under this

system the ownership of the goods are not transferred to consumers at the sales point. Consumers

are understood to lease the goods and return the goods after consumption to producers.

2) Why producers?

Why producers should have this expanded responsibility? It is only because producers are in

a best position to promote recycling. (i) Producers decide the materials and structure of their goods

which have a great impact on the recyclability of the goods. By adopting DfE producers can change

materials and structures of their goods for easier recycling. (upstream control) (ii) Producers can

provide recyclers with information for recycling job by disclosing the structures, kinds of materials

used and other features and properties. of their products. (iii) Producers can provide an efficient

logistic route for the post consumption by making use of the distribution channel of their products. (iv)

Producers can contribute to creating and expanding markets for the recycled goods being big

consumers of recycled materials. (v) Producers are in the best position transferring the recycling cost

to other agents, eventually to consumers. (vi) Finally, and most importantly producers are responsible

for the over consumption of modern consumers(and so excessive waste generation) as they provoke

people to buy with aggressive sales promotion strategies through massive ads and commercials.

4.2 who are producers?

EPR does not consider only the manufacturers accountable for the environmental impacts;

this responsibility is extended to all those involved in the product chain from manufacturers, suppliers,

retailers, consumers and disposers of the products. Sometimes EPR is called as SPR (shared

producers responsibility). In England, sharing of the responsibilities all the agents in the same product

chain is explicitly stipulated, while in the rest of the countries the sharing is left to self reallocation of

the agents themselves are given different share of recycling obligations.

There are two groups of waste subject to EPR system. Packaging waste and durable goods

waste. For packaging waste bottlers(fillers) using the packages are the producers responsible.

Domestic fillers and importers are included. For durables waste, manufacturers and importers of the

durables are producers. Manufacturers and importers are responsible producers in the case of

fluorescent lamps and other mercury containing waste.

Manufacturers, importers, wholesalers and retailers, all the agents in the product chain are

responsible and responsibilities are shared among them. In English version obliged recycling rates

are assigned to all the agents. Each agent is assigned its own target rate. In other European and

Korean versions, one agent with greatest market power is selected as prime producers who are

assigned legal duty. The prime producers are expected to reallocate their burden among all the

agents in the product chain by transfer mechanism. The brand name owners are believed to have the

greatest market power and selected as the prime producers. In Japanese version, local authorities are

included among the agents to share the burden. Producers are responsible only for the collected

quantity by local authorities.

4.3 Duties and responsibilities of producers

1) manufacturers/importers

Their responsibilities are two folds; responsibilities in the stage of production and in the stage

of post consumption. Producers, in the stage of production, must try to change the structures and

materials through DfE( design for environment), for easier recycling, less use of packages, extended

longevity, and strengthened durability, and must disclose the product information for the use of

recyclers. Producers, in the phase of post-consumption, must recover their post consumption

products to the mandate recycling target. The target is decided as the rate of the sales volume.

Producers, for the recycling obligations, must report sales volume, submit recycling plan with their

facilities and manpower showing their capacity or contracts with licensed recycling companies, and

report the result(completion of obligation), In case of non-compliance or less compliance must pay the

penalty(recycling charges).

2) wholesalers and retailers

Often wholesalers are assigned to collect the post-consumption by running collection center

or simply accept the used goods collected by retailers. Retailers are assigned to collect post

consumption for free on consumers request. For FLW case, retailers can be forced to run an

exchange program under which retailers can sell new lamps in exchange of used ones. Producers

and wholesalers retailers all should try to promote return of the used lamps introducing incentive

programs

4.5 Methods of complying with recycling obligations

Producers must be allowed to entrust other recyclers with their recycling jobs, since most

producers do not have facilities or other means to recycle their post-consumption and are generally

given options in complying with their recycling obligations; self recycling or consigning., And most

countries have a system for joint recycling of producers, called PRO (Producers Responsibility

organization). The PRO is a voluntary organization of EPR producers to meet the obligations together.

1) Self recycling

Producers, for self recycling, must have own collection, transportation and treatment facilities

and should have license for those work with enough manpower and equipments. They must report on

their plans and facilities showing their capacity and are subject to pre-examination by government

authorities. They must report the result and be examined the achievements and compliances with the

rules and procedures in their all the stages of recycling jobs.

2) entrusting

Running a recycling business is not regulated provided that the recycling methods and

process satisfy the rules and do not make any harm to people or environment. The recycling business

which is entrusted with the recycling obligations by producers must have licenses from the

government. I issuing licenses, government must confirm their ability to recycle the entrusted quantity.

Government pre announce the conditions for obtaining recycling business licenses. The conditions

include equipments and manpower for collection, recycling facilities and units for the kind of

technology they adopt, and other facilities and equipments. Producers can consign their duties only to

the licensed recycling companies. Producers must submit recycling plan with contracts with the

licensed recycling company. Producers report the result with certificates of recycling by the contracted

company. Producers are responsible not only for the non-compliance or un-recycled post

consumption but also for the cheating, fraud, or illegal maneuver by the consigned company.

3) join a PRO(Producers responsibility organization)

Producers can organize their own association to perform their obligations jointly. Government

issue permit the associations to do all the activities for meeting the EPR obligations on behalf of

member producers. The PRO make all the reports, make contract for the recycling job with the

licensed recycling companies, collect membership fees, pay the recycling cost and responsible for all

the recycling performance and the recycling activities. Producers are exempted from all the

obligations by joining a PRO. Producers do not make any reports and are not responsible for the non

or less recycling than the mandated target rate or any kinds of mis-maneuvers by PRO or its contract

companies.

4.6 Recycling targets

Government decides total quantity to be recycled for the target year, considering the

capacities of collection agents, Local authorities, private companies and other collection agents and

the capacity of recycling facilities. This target quantity is converted into target rate of recycling by

dividing the target quantity by estimated waste volume. Waste volume is estimated as the same as

the sales volume for the case of packaging waste and calculated as some percentage of sales volume

considering the average year of use. The target volume of recycling of fluorescent lamps waste will be

estimated the sales volume and the average year of use based on the survey result. (appendix)

Individual producers are given target quantity by multiplying the target rate to their sales volume

(generally the sales volume of the previous year). Government usually operates a meeting of

producers and other stakeholders to decide the target rate of recycling for each product.

4.7 Penalty for noncompliance

Producers and/or PROs are levied penalty for the case of non or less compliances of the

obligations. Fine, generally called recycling charges, is decided at the level for government doing the

recycling of the waste. The unit recycling cost is estimated and pre announced as standard recycling

cost by government (appendix) Governments run a banking system issuing credit for the excess

recycling over the obligated quantity. Producers can use the excess recycling quantity over obligation

for the next years’ obligation.

4. 8 Exemption of obligations

In principal al the producers should be given recycling duties in proportion to their sales or

waste generation. But for small companies it may be a great burden financially as well as physically.

Sometimes it may be a severe disturbance or obstacle to normal business operation, and their

recycling volume is so small that nearly negligible contribution to overall recycling target. In many

cases of small business, the administrative cost exceeds the benefit of recycling. In addition,

government does not have enough manpower to control and monitor all the small enterprises. There

must be some exemption of duties. Most countries exempt small companies with sales less than

standard amount and/or sales volume less than standard volume from the recycling obligations. The

exemption criteria for fluorescent lamps waste will be decided later in the third phase when the EPR is

actually implemented, considering the relative weights of small companies in the total waste volume

and manpower in charge of the administrative job.

Chapter5. Implementation plan for establishing IWMS for mercury containing

waste

5.1 Goal

The final goal of this implementation plan is to develop the capacity of Egypt to deal with

mercury containing waste by achieving sub goals of (i) upgrading public awareness, (ii) construction

of recycling facilities and other infra structures for collection and transportation of full collection and

treatment of mercury contained waste from all sources, (iii) establishing a stable financing system

based on the polluters pay principal, and (iv) full development of waste industry where private

enterprises run business for commercial profit by 2020. Ideally governorates will have recycling

facilities (private or public) in their regions and developed their own efficient collection system by 2020

and most of the actual activities of collection and treatment will be undertaken by private companies in

contract with local authorities or independently for purely commercial profit. All these goals can not be

achieved in one time and takes a very long time, so here a gradual or phase-wise development

strategy is recommended.

5.2 Phase-wise strategy of implementation

The whole plan can better be implemented in three phase of starting and preparation,

expansion, and development. The first phase is the completion of the KOICA project for the normal

operation of the pilot facility to be constructed by the project with all the legal and other administrative

preparations. In the second phase Egypt make its own master plan for expansion of the scope of

waste and sources and implement it with own ability by constructing facilities and other infra

structures out of its own sources. Financing will be made out of private funds by making an

environment for private business. In the third phase all the systems and infra structures are

established to cover all the waste from all the sources. By this time the EPR system is completed and

commercial business will take care of most of the collection and treatment of hazardous waste.

1) 1st phase: 2010-2012: KOICA PROJECT period

KOICA initiated preparation for introducing an IWMS for mercury containing waste is

undertaken during this first period. The main goal is to build the capacity of Egypt government for self

management of the mercury containing waste. For this purpose, a professional consultancy for

designing an integrated management system for municipal hazardous waste, manpower training

services are provided by KOICA with the construction of a pilot facility for FLW recycling. By the end

of the 1st period, the Egyptian government must have a design of integrated management system for

the municipal hazardous waste, an implementation plan which includes construction plan of

infrastructures(number and capacities of facilities) for the waste management, financing plan for the

investment and operational cost, manpower training plan and program. Tasks to be undertaken are (i)

survey on the status of the mercury containing hazardous waste management, (ii) design of an

integrated waste management system for mercury containing hazardous waste (iii) making a master

plan for introducing the IWMS, (iv) construction and operation of the pilot facility by KOICA project.

The scope of waste is confined to defected fluorescent lamp goods generated by manufacturers.

Expansion of the scope of waste can be considered after the normal operation of the pilot facility and

after construction of new facilities and establishing collection scheme in the target governorate

area/region.

2) 2nd phase: 2013-2017

In this following phase the Egyptian society must establish a sound foundation for the IWMS

with government initiation. The government people trained by the KOICA program and government

agencies which have experience of facility operation will initiate the business and promote private

participation in the field of hazardous waste collection and treatment business. The enhanced public

awareness in the 1st phase will contribute to establishing a culture in favor of recycling putting

pressures on assigning producers recycling responsibility making the government can have legislative

framework for introducing a responsibility sharing system like EPR or other financing scheme.

With the new financial sources government can construct infra structures and induce private funds for

the construction of facilities. Commercial operation of the facilities is popularized governorates assist

the private business by making contract and ensuring profit, and/or providing spaces and equipments

for easy collection. The scope of waste is expanded to used old lamps by big users from commercial

sectors of commercial buildings, factories, business sites.

Tasks to undertaken in the second phase are (i) Construction of facilities in major

governorates regions, cities and districts. (ii) Establishing a nation-wide unified collection system

ideally by private companies, (iii) Establish an environment for private business

3) 3rd phase: 2018-

This phase completes all the missions. All the infra structures are built and all the systems

are completed to cover all the mercury containing waste from all the sources. Most collection and

treatment are conducted by private enterprises on the commercial profit basis. an EPR system is

completely implemented to assign all the producers of mercury containing goods responsibilities for

recycling and other activities. A stable financing scheme is established and financial assistance by

producers are made for the commercial operation of collection and treatment works. All the

governorates will have a nation-wide unified collection system, various collection centers,

transportation routes and modes, treatment facilities with enough capacity to treat all the collected

volume, supported by legal frameworks and manpower supplying system.

The scope of waste will be expanded to cover all mercury containing waste from all sources. Tasks to

be completed in this phase are (i) Responsibility sharing among LAs and all the agents related with

waste generation, (ii) legal and socio-economic settlement of the responsibility sharing, (iii) a full

privatization of the hazardous waste business.

Following table shows goals and strategies for each phase.

1st phase 2nd phase 3rd phase

2010 2011 2012 2013 2014 2015 2016 2017 2018-2020

waste defected goods post- consumption waste

sources manufacturerscommercialbig users

public big users households

regions all nations CairoGreater Cairo

Greater Cairo/Big cities

Cities

infrastructures pilot facility

- new facility(private)- collection center

- new facilities(private/public)

- new facilities (public)

legal and administrative

systems

- regulating manufacturers- regulations for recycling activities- organization in charge of control and supervision

-discharging practice

financing system

- establish PPP- incentive programs for private funds

- volume rate waste fee - exemption for separated waste

- EPR- consumer deposit- exchange program

5.3 Construction plan of Infrastructures

1) Construction of FLW recycling facilities

to be completed after survey completed

yearNumber of units

waste treated capacity sources

2010 1 defected goods manufactures in Cairo region

2012 1 defected goods all manufactures

used old lampscommercial sectors in Great Cairo region

commercial sectors in all big cities

public sectors

all the sources, all the regions

other mercury waste

5.4 Estimation of cost and financing (to be completed after survey)

yearNumber of units

investment costoperation

costfinancing sources

2010 1 manufactures

2012 1 manufactures

2013 commercial users

2014 commercial

2015Local authorities, fund from EPR (producers)

2016

2017

2018

5.5 programs for upgrading public awareness

school education: distribution of education materials, special train of teachers

public campaign: media programs , public advertisement

distribution of phamplets and other materials

to be completed after discussions with Egyptian government officials

5.6 Manpower supply plan

making and implementation training plan

establish institutes

develop training programs and materials

to be completed after discussions with Egyptian government officials

5.7 post plan

The basic plan for reducing the environmental contamination by mercury waste is

replacement of the mercury containing goods with non-mercury goods. For mercury battery cells

already other substitutes are developed so some program for discouraging the use and production of

mercury battery cells is recommended. Simply the use and production can be banned. Most gages

and gadgets using mercury can be substituted with other non -hazardous goods. Legislative

measures banning or regulating the use and production can be applied in accordance of technological

development. For fluorescent lamps, LED can be a good alternative. Because of the high prices of the

LED products, enforced substitution is not feasible. Efforts to down the manufacturing cost by massive

purchase by government sector through a renewal plan of public buildings and schools should be

implemented with some subsidy programs for the domestic manufacturers

Chapter 6. Action plan for the 1st phase

6.1 Legal framework

1) reclassification of waste

It is needed to define defected fluorescent lamps as industrial hazardous waste and assign

manufacturers responsibility for management of the waste. Manufacturers must report the volume of

waste, and treat in the regulations for collection and treatment of the mercury contained waste.

Used old fluorescent lamps and other mercury containing waste from non-industrial sector are

classified as hazardous municipal waste subject to special regulation in dealing with the waste. The

other mercury containing wastes are mercury battery cells, thermometers, barometers, rectifier and

catalysts.

2) assignment of responsibilities

Manufacturers are assigned responsibility for self treatment of the defected fluorescent lamps

with own expenses. In case of legislation is not feasible within the time period, voluntary agreement

between manufacturers and government (EEAA) can be an alternative. The voluntary agreements are

backed by some threatening for strengthened legislation in the future. Local authorities, governorates

or CEO of districts and cities should be given responsibility to collect the old lamps separate from

other municipal waste and take measures for separate discharge and collection. They are encouraged

to rune incentive programs for commercial operation of facilities and collection business. This also can

be implemented by voluntary agreements between ministry of environment and LAs before any

legislation.

3) government organization

There is needed a government organization for overall control and administration of mercury

containing waste. According to current EEAA organization, section for hazardous substances and

waste is the best section for those affairs. It is in charge of making rules and standards for overall

control of the waste activities by making new laws, revising existing laws and acts, making conditions

for licensing waste treatment facilities and operating business, regulations to be complied in

undertaking the waste collection, transportation, treatment, and disposal activities.

There must be organized an independent government agency under the hazardous

substances and waste sector which will be in charge of supervision of the fluorescent lamp waste

recycling facility operation. The agency will make operational guidelines, emergency plans, and

analyze the recycling cost to decide standard waste treatment fees which will be used as a refenece

for the contract between operators and manufacturers.

4) regulations for recycling activities

- discharging practice

All the users of fluorescent lamps should separate used lamps from other waste and garbage

and place them unbroken at the containers or boxes with cautions not to break. Any intended

breakage of lamps are penalized.

- specifications of collection box

- placement

- management

- methods of collection

old lamps must be collected by licensed trucks with roof covered to prevent leaks of falling

during the transportation with facilities to absorb shocks to prevent breakage

- methods of recycling and treatment

The operators must use the glass as raw material for making new glass material or glass

products and recover mercury as a metal mercury or mercury compound using the absorption units

that satisfy the government specification. .

- conditions for license

Anyone who plans to operate fluorescent lamps recycling or other treatment facilities must

have licenses from the government before he starts the operation work.

* specifications for recycling facilities

sites

units

other auxiliary facilities

to be completed by unit manufacturers

6.2 Preparing basis for commercial business

In order to facilitate commercial operation of the facility and induce participation of private

funds government must show the profitability of the facility operation in the first phase. Government

must ensure the qualifications of operators in selecting the first operator of the facility for the stable

operation without any technical or operational problems encountered. Government must also ensure

enough revenue to finance the operational cost and depreciation cost. Depreciation cost may be

accumulated in a separate account for the future construction programs. For this purpose government

must conduct cost analysis and to estimate future operation cost. Most of all there must be strong

measures to enforce manufactures to recycle their defected goods by making contract with the facility

operators.

Appendices

1. summary of survey

to be completed

2. Rules and standards for collection and transportation and specifications of collection

box

will be provided by unit suppliers.

3. cost estimation

to be revised after all price data are collected

collection, transportation, processing

Cost itemsUnit Cost

ReferencesKorea Egypt

Collection costs

Collection cost

Labor costs172

0.688

Depreciation costs (vehicles)

80.032

Vehicle maintenance costs

170.068

Subtotal197

0.788

Storage and cargo-handling

costs

Labor costs104

0.416

Depreciation costs (instruments)

-

Maintenance and repair costs (instruments)

-

Land costs4

0.016

General operation costs (labor costs)

-

General operation costs (others)

150.060

Subtotal123

0.492

Transport costs

Labor costs46

0.184

Depreciation costs (vehicles)

60.024

Vehicle maintenance costs

110.044

Subtotal63

0.252

Operation cost

Cost items Unit Cost References

Korea Egypt

Processing costs

Labor costs24

0.096

Deprecation costs (instruments)

600.240

0.240

Maintenance and repair costs (instruments)

190.076

0.076

Waste processing costs13

0.0520.052

Material and other costs23

0.0920.092

Land costs3

0.012-

General operation costs (labor)

220.088

General operation costs (instruments)

60.024

0.024

General operation costs (others)

80.032 0.032

Subtotal177

0.708

Cost itemsUnit Cost

ReferencesKorea Egypt

Processing costs

Labor costs 0.096

Deprecation costs

(instruments)2.400 2.400

Maintenance and repair

costs (instruments)0.076 0.076

Waste processing costs 0.052 0.052

Material and other costs 0.092 0.092

Land costs 0.012 -

General operation costs

(labor)0.088

General operation costs

(instruments)0.024 0.024

General operation costs

(others)0.032 0.032

Subtotal 0.708

price of new FL

4. comparison of acts and laws revision

to be completed after all the material are collected

Name/clause current revision

Prime Minister's Decree No. 338 of 1995

defected flourescent lamps are not included as hazardous waste

dfl classified by hazardpous industrial waste

Refenence: related clauses

Law 4

Chapter II

Hazardous Substances and Waste

(Flourescent lamp producers)

Article (25)

It is forbidden to displace and use hazardous substances and waste without a license from the

competent authority indicated for each as hereinbelow:

2. Hazardous industrial substances and waste - Ministry of Industry.

7. In respect of other hazardous substances and waste, the respective bodies competent to

issue a license for their displacement shall be designated by a decree of the Minister for

Environmental Affairs on the basis of a proposal by the CEO of the EEAS

(recyclign facility operator)

Article (26)

Procedures for granting a license:

Conditions for granting a license:

Article (27)

- for a maximum period of five years subject to renewal.

- The licensing authority may revoke the license or suspend the activity

Article (28)

The management of hazardous wastes shall be subject to the following rules and procedures:

1- Engendering Hazardous Waste:

A-Try hard to reduce the rate at which such waste is produced,

B-Categorize the waste produced, in terms of both quantity and quality, and register same.

C-Establish/operate units to treat waste at source, with the EEAA approves.

collect and transport it to the disposal sites determined by the local authorities and the competent

administrative and environmental bodies.

2-Stage of Collecting and Storing Hazardous Waste:

A- locations for the storage

B- Store hazardous waste in special containers made of a solid, non-porous, leak-

proof material.

C- Place a clear sign

D- Lay down a schedule for the collection

3-Stage of Transporting Hazardous Waste:

5-Stage of Treatment and Disposal of Hazardous Waste:

A-sites

B-Processes reutilization

C-Processes disposal

D-limiting and reducing

E-monitor the sites of utilities and their surroundings for the treatment and disposal of

hazardous waste.

F-responsibility for damage caused to third parties

Article (29)

It is prohibited to construct any establishment for the purpose of treating hazardous waste except with

a license issued by the competent governorate after consulting the EEAA, the Ministry of Health, the

Ministry of Labour and Manpower, and the ministry concerned with the type of waste according to the

provisions of Article (25) of these Executive Regulations, after ensuring that such establishment

satisfies all the conditions which guarantee the safety of the environment and the staff employed

thereat.

The Minister of Housing, after consulting the ministries of Health and Industry and the EEAA, shall

determine the locations and conditions for the disposal of hazardous waste.

Article (33)

The owner of an establishment whose activity results in hazardous waste pursuant to the provisions of

these Executive Regulations shall be held to keep a register of such waste and the method of its

disposal, as well as of the names of the parties contracted with to receive the said waste, as follows:

1) Name and address of the establishment.

2) Name and job title of the person responsible for filling in the register.

3) The period covered by the current data.

4) The special conditions issued for the establishment by the EEAA.

5) A list of the types and quantities of hazardous waste resulting from the establishment

activity.

6) Method of disposal thereof.

7) The parties contracted with to receive the hazardous waste.

8) Date on which the form is filled.

9) Signature of the officer in charge.

Article (57)

No building permit shall be granted for the construction of any establishments or public places on or

near the seashore which would result in the discharge of polluting substances in violation of the

provisions of the Law, of these Executive Regulations and of the decrees issued in implementation

thereof unless the provisions of Chapter I of Part One of these Executive Regulations relating to

development and the environment are duly observed. The permit holder shall provide suitable and

adequate units for the treatment of waste which he shall begin operating promptly when the

establishment commences operations. He is held to secure the safety and maintenance of these units

on a regular basis.

2) Executive Regulation of LAW NMBER 4 of 1994 EGYPT prime minister’s decree No. 338 of

1995

Chapter IV Incentives (for the inducement of private funds)

Article (9)

Within six months from the date these Executive Regulations come into force, the EEAA shall, in

collaboration with the Ministry of Finance, lay down a system of incentives which the EEAA and

competent administrative bodies may offer to agencies, establishments, individuals and others who

undertake activities or projects that protect the environment, provided due consideration is given when

laying down such system to the privileges and conditions prescribed in laws and decrees, particularly

to those related to investments, customs, industry, cooperatives and others.