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5. Review of EU and national measures to reduce the potentially toxic elements and organic content in wastewater and sludge

5. REVIEW OF EU AND NATIONAL MEASURES TO REDUCE THE POTENTIALLY TOXIC ELEMENT AND ORGANIC CONTENT OF WASTEWATER AND SEWAGE SLUDGE.

5.1 Approaches to reducing pollutant content of wastewater and sludge As has been shown so far in this report UWW treatment is not sufficient to deal with all . Most of the pollutants are concentrated in sewage sludge although different contaminants end up to varying degrees in effluent from WWTPs. This effluent ends up in aquatic environments. Concentrating pollutants in sewage sludge, while it may protect receiving waters, presents a number of problems for its disposal or use on agricultural land.

Because of this, a variety of instruments have been attempted at national level, with varying success, on different levels to reduce UWW pollution closer to at source. These instruments are consistent with an overall strategy of minimisation, polluter pays, and reduction at source and include individual regulatory, economic and voluntary and educational instruments. Table 5.1 Summary of Available Instruments Instruments Regulation Economic Voluntary Educational

Direct Licensing of “Downstream” Agreements and Research into Measures disposal to Charges and Management alternative (Applying to UWW taxes on Systems products and direct inputs Licensing of disposal to directed at processes, to UWW) product use UWW Integration of Subsidies for minimization or and Waste Water alternative alternative Minimisation Management technologies, collection Training and UWW into substances or and collection Spatial Planning services Trading of pollution reduction credits Indirect Product and “Upstream” Agreements, Research into Measures Substance Bans Taxes and Management alternative (applying to Product and Charges on Systems and products and indirect or Substance Use Particular Inputs Codes of processes, diffuse Licensing Subsidies for Practice aimed Management sources) Integration of alternative at alternative and Waste Water management management Minimisation Management and products strategies Training and UWW into Trading of Labelling and Land Use and pollution Specific and Spatial Planning reduction credits General Publicity Measures

The following selected examples demonstrate strategies for the minimisation of waste at source through these instruments:

· Regulatory Instruments: · The Prohibition of Clinical Thermometers in France · Economic Instruments: · Wastewater Tax in Germany · Charges on in Fertilisers in Sweden

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· Subsidies to in the Dry Cleaning Industry in France · Voluntary Initiatives: · Targeted Waste Collection in France · Strategy in Leather Industry in Italy · The Anjou Recherche Programme and Special Conventions in France · Local Initiatives, Promotion of Environmental Management and in Denmark. · Educational Initiatives · Provision of Consumer Information in France · Eco-labeling and LAS in Scandinavia · Awards Company Innovation in Waste Management and Minimisation in France

These measures may be differently targeted, to general and particular discharges or to product use and substitution, to specific processes and industries and , or to specific localities and catchment areas.

5.2 Regulatory Instruments

The use of traditional command and control instruments involves licensing of the use and discharge of material to UWW. This approach is notoriously difficult to monitor and control effectively. In the case of particularly difficult pollutants, targeted product bans can be a more cost effective solution where clear alternatives are available and the production of the material in question is relatively easy to regulate.

The Prohibition of Mercury Clinical Thermometers in France

Mercury is used in a broad area of applications. Industrial uses of mercury may be found in the electro-technical industry to produce batteries or fluorescent tubes or in dental practices for fillings. Other industries require mercury for the production of instruments such as manometers, barometers and thermometers. It is estimated that the total production of mercury in France for industrial productions amount to an average of 60 tonnes per year.

Impact: Mercury is of particular health concern for not only are humans exposed to mercury directly when the product breaks, but they also may be exposed after it is disposed and accumulates in UWW and sludge. It can also leach from through the water waste pathway or be directly released in the wastewater system after disposal in sinks and toilets – raising concern for the risk of human exposure and environmental contamination. It is also estimated that before the introduction of the ban on the marketing of clinical mercury thermometers, an average of 15 – 20 million mercury-thermometers were in circulation in France. These are equivalent to 12 tonnes of mercury – about 20% of the yearly amount produced. It is also estimated that an average 1.5 – 5 million of these thermometers were broken every year, releasing between 3 and 10 tonnes of mercury in the environment yearly and causing significant health and environmental concern. (Romp, 1993 in Öko Institut, Berlin).

Measure: Under the new French regulation [Arreter of 24 December 1999, Journal Officiel, 31 Decembre], the marketing of clinical mercury thermometers is prohibited both nationally and at EU level, as from March 1, 1999. However, the enactment does not prohibit export to non-EU nations. The main objectives of the ban being that of minimising mercury waste and prevent its release into the environment, hence reducing risk to humans.

Costs: Although difficult to evaluate precisely, the implementation of the regulation resulted in two types of costs: 1) Reprocessing Costs associated to the reprocessing mercury thermometers and 2) Replacement Costs for the purchase of new (electronic or eardrum) devices. The average cost of an electronic thermometer ranges between 11 and 30 EURO

103 5. Review of EU and national measures to reduce the potentially toxic elements and organic pollutants content in wastewater and sewage sludge per unit, whilst a professional device costs around 305 EURO. The cost of an eardrum thermometer (an infra-red device) ranges around 69 EURO. The professional timpanic device costs between 305 and 610 EURO. Assuming that at least 15% of mercury thermometers are collected in the first year, the total cost of the scheme amounts to about 3.81 million EURO. Effectiveness: Although still at its early stage, the ban has been very successful and other nations such as Germany and Sweden are already following similar policy measures. It is estimated that the ban will reduce mercury waste by 12 tonnes a year – a reduction of 20% of the total annual mercury production in France. However, such action should also be taken for other industrial sectors using mercury - and French policy is seemingly moving towards this direction – so as to further minimise the quantity of mercury present in the environment and reduce the risk to human health and the environment.

Economic Instruments

Economic instruments may be used to provide a continuing incentive for reduced use of a material and even product substitution. Nevertheless; evidence suggests that taxes and charges need to be carefully designed and targeted so as to promote continuing waste reduction. The social and economic implications of taxes and charges may make their introduction controversial, and the costs of their administration can make them as complex to administer as command and control regulation.

Wastewater Tax in Germany

This measure is a “downstream” charge on discharges, and demonstrates how the creation of economic incentives alone may not be more effective in promoting reductions than command and control measures.

Measure: The Federal Wastewater Tax was adopted in September 1976, comprising a tax on sewage discharges; the amount payable was established on the basis of the amount and harmfulness of the waste. The objective of the tax was better regulation of discharges and to promote a reduction in wastewater pollution over all

Effectiveness: In terms of offering an overall incentive to reduce discharges, the impact of the measure was found to be limited. A study carried out by Jass (1990) conclude that while the charge had to considerable improvements of the purification of sewage and the , it had not constituted any incentives for further improvement. Sewage taxes only created an incentive to comply with the command-and-control regulation, but nothing more (Lubbe-Wolf, 1996 in Cremer and Fisahan, 1998)

Charges on Cadmium in Fertilisers in Sweden

This is an example of a specifically targeted measure. Sweden has had environmental charges on nitrogen and phosphorus in commercial fertilizers since 1984. The “downstream” charge on phosphorus was abolished in January 1994 and replaced by an “upstream” charge on cadmium.

Measure: An important reason for the introduction of the cadmium charge was that it creates an ongoing incentive to reduce the concentrations (Swedish EPA, 1991) in fertilizers. Since November 1994, the charge rate is SEK 30 (EURO 3.3) per gramme of cadmium if the cadmium content exceeds 5 mg per kg phosphorus (about 2.2 mg Cd per kg P2O5) (Swedish EPA, 1997).

Impact: According to the Swedish Board of Agriculture, the content of cadmium in fertiliser has gradually fallen from 35-40 mg Cd per kg phosphorus (before the introduction of the

104 5. Review of EU and national measures to reduce the potentially toxic elements and organic pollutants content in wastewater and sewage sludge charge) to about 23 mg in 1994/95 and 16 mg in 1995/96. The Board conclude that the Cd charge in combination with the demand (for a low content of Cd in fertiliser) by the agricultural sector has kept Cd levels on a low level (Jörnstedt, 1998). Drake and Hell-Strand (1998) concluded that the combination of governmental policy (including the charge and a standard) and voluntary efforts has been successful in reducing the content of cadmium in phosphorus fertilisers. However, it was not possible to estimate the relative importance of the different measures.

Costs: State tax gross revenues in 1996 were around 10 million SEK (1 million EURO), and the administrative costs are estimated to be around 1% of the gross revenues (Drake and Hellstrand, 1998). The tax is administrated by the National Tax Board, together with the tax on nitrogen. Importers and producers report quantities and contents every month. The only control made seems to be ‘tax audits’ (concerning the accounting of the firms involved). In 1999, 25 such audits were performed (corresponding to about one ‘man-year’). The authorities do not measure the actual cadmium content of fertilisers. Some problems with illegal imports by small firms of fertilisers from Poland and the Baltic states (probably of Russian origin) are reported (Jörnstedt, 2000).

Subsidies to Waste Collection in the Dry Cleaning Industry in France

A very good example of an economic instrument is where competent authorities find it cheaper or more effective to subsidise alternative production processesses or waste collection strategies than to treat a particular pollutant.

For the businesses using chlorinated solvents, currently only two main options are available to deal with the waste: regeneration of the solvent (10%) and (90%). The problem with regeneration is that the process may affect the added stabilisers, which are required for the stability of the solvent at high temperature and humidity. Hence, it is necessary to treat the regenerated solvent with new stabilisers. Nevertheless, it is usually cheaper than destruction of the waste, which in France costs around 4100 FF per tonne. However, generally only larger firms employ this solution.

Measure: Associations have been created in the dry cleaning sector in order to organise widespread regeneration of solvents, and these are starting to cover other solvent using sectors. These organisations co-ordinate the collection and treatment of . The Agences de l'Eau subsidise dry cleaners who adhere to these associations in order to help finance the cost of the collection of their wastes.

Costs: A typical dry cleaning facility produces 400 kg of chlorinated waste per year and the cost of collection and treatment is around 3500 FF per year, which represents about 1% of their revenue [ADEME, 1995].

5.4 Voluntary Instruments and Government Industry Cooperation:

“Voluntary” instruments encompass a range of policy initiatives, from industry initiatives based on EMAS and other management and auditing systems, to agreements between organs of the state and industry. Voluntary Instruments however are very rarely just that, and often operate as part of a broader scheme of regulation, economic incentives (including subsidies) and public education exercises. The division of responsibility and costs between government and industry varies from case to case.

Some instruments amount to an indirect subsidy to industry, others enforce the by creating an incentive to manage waste through the adoption of producer responsibility, as in the directive. The following examples include a range of instruments adopted by government and industry in cooperation, including targeted

105 5. Review of EU and national measures to reduce the potentially toxic elements and organic pollutants content in wastewater and sewage sludge collection of problematic wastes, voluntary and regulatory or economically inspired waste minimisation strategies. All imply some proactive governmental intervention.

Targeted Waste Collection in France

This measure constitutes a specific drive and effort by authorities to collect dangerous and harmful waste from homes. While effective in its own terms it is not a long-term solution to the problem of discharges to UWW. It may be effective to deal with continuing risks of contamination from smaller and diffuse sources, and be used in connection with the adoption of a longer-term waste minimisation and collection strategy and public education campaign.

Measure: One of the first targeted waste collection initiatives carried out in France was in 1989, where 11,500 kg of waste products were collected over 16 days (see Table 5.2).

Table 5.2 Quantities of products containing pollutants collected at Savie in 1989 [ADEME, 1995]

Product Amount (kg] Percentage of total Waste Collected Paint 5590 48.6% Solvents 2360 20.5% Medicines 1010 8.8% 1005 8.7% Chemical laboratory products 70 0.6% Thermometers 65 0.5%

Costs: A more recent example is given by the 2 day collection in 1994 in the area of Boisset-Gaujac (Gard) where 114 kg of chemical products, 169 kg of paint, 12 kg of , 27 kg of solvents, and 29 kg of products were collected and dispatched separately for treatment at a cost of about 12,000 French francs [ADEME, 1997]1.

Effectiveness: Experience has shown that is it more efficient to appropriately equip waste reception centres for handling special wastes rather than organising random collection days. In contrast to targeted waste collection, the adoption of a comprehensive waste minimisation strategy directed at particular sectors has demonstrated longer term and verifiable results.

Waste Minimisation Strategy in Leather Industry in Italy

This is another example of targeted intervention by public authorities, this time engaging a particular sector in the long-term management of industry specific problems.

Italy is the principal European location for the leather and tannery sector in terms of establishments, employment and production. Tanneries are mostly small and medium sized enterprises, with only 10% of them employing more than 20 people. The industrial area covered by the plan is located in the Valle del Chiampo, in the province of Vicenza. The area embraces 10 municipalities, of which Arzignano is the most important with more than half of the tanneries. The tannery area is the largest in Europe and supplies 50% of the Italian production. includes shoes, furniture and other leather goods (Vicenza Dept. of Environment, 1997)

Impacts: The tannery industry is considered to have important environmental effects on both water and air, primarily because of toxic wastes generated by the large amounts of chemicals employed during the various phases of the process. The main pollutants

106 5. Review of EU and national measures to reduce the potentially toxic elements and organic pollutants content in wastewater and sewage sludge being III, sulphur, chlorides, solvents and organic wastes. (Vicenza Dept. of Environment, 1997). The tanning process comprises two phases - covering and fixing, where the pelts are sprayed with paints and chemicals for treatment. It is estimated that around 80% of the solvents used become and 1997data from the Dept. of Environment of Vicenza indicate that the solvents used for the finishing process amount to 20.000 tonnes per year, 85% for the covering phase, 15% for the finishing phase. Metoxy propanol is the solvent most used in tanneries and is classified as Class III hazard substance under Italian law, which has 5 classes of hazardous substances for which maximum allowed emissions are set.

Measure: In 1997, the Dept. of Environment of Vicenza introduced new measures to tackle the environmental problems of the spray finishing process. The intervention focused on two main aspects: 1) the introduction of innovative machinery, such as the more efficient low pressure airbrushes or high pressure airless brushes instead of high pressure devices; plus 2) the use of chemicals dissolved in solution. ‘Gruppo Conciario Veneto’ a tannery association comprising 4 companies (La Veneta, Conciaria Adriatica, Sacpa and Veneta Conciaria Valle Agno), with a total of 340 employees, 26.500 m2 of indoor plant and a 1997 turnover of 103 million. EURO, adopted a scheme reducing use of, and ultimately replacing, the solvent metoxy propanol with alternative substances. Other substitutes are currently being tested.

Effectiveness: As a result of the waste minimisation scheme, the use of Metoxy was significantly reduced from 7,300 kg in August 1998 to 1,300 kg in December 1998 (- 82%), but has been replaced by the less hazardous isopropyl alcohol (Class IV), which has in turn increased in consumption. However, the total quantity of solvent used decreased from 10,650 kg to 5,007 kg per month (- 53%) and therefore less has been generated and released by the tannery (no quantitative data available).

Costs: The reduction in utilised solvents also brought significant economic benefits, with a reduction in monthly consumption equivalent to 64%, from 10,590 EURO in August 1998 to 3,794 EURO in December 1998. These economic savings appear to be the main incentive and persuasive tool to company innovation.

The Anjou Recherche and ‘Eaux Industrielles Initiatives’: Special Conventions in France

These cases are further examples of targeted intervention at the local level, representing a programme of sources and discharge identification, and the first example of a truly “voluntary” initiative through the adoption of negotiated approaches to the reduction of problematic discharges.

Measure: Anjou Recherché has studied five regions of France which have full statistical data and 34 UWW collecting systems. This research programme allows many SME polluters to be identified. Following the identification of industries that are potential polluters, a contract is drawn up between local industry and the mayor of the area. The contracts are called special conventions for discharge, and about 2000 have now been set up, mainly in the South West region of France around Toulouse. The contract determines pollution reductions and modifies discharge conditions into the UWW collecting system.

In Tours the "eaux industrielles" initiative was established in 1988. This initiative aimed to control the quantity of discharges into the UWW collecting system based on monthly analyses on the sludge quality are carried out to control for pollution. In 1996 it was found that copper and mercury concentrations were very close to the recommended limit and much higher than the averages for France (Table 5.3).

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Table 5.3 Average concentrations (g t-1) in potentially toxic elements in the Tour sludges [from ADEME, 1997] *French Standard NF U 44 041

Average Average French Standards concentration concentration (Tours) (France) References Limits Cd 5.3 5.3 20 40 Cr 96 80 1000 2000 Cu 805 334 1000 2000 Hg 7.3 2.7 10 20 Ni 106 39 200 400 Pb 153 133 800 1600 Se 3.5 7.4 100 200 Zn 977 921 3000 6000

Visits to the businesses potentially capable of releasing copper were undertaken and it was found that the problem initiated from a mirror manufacturing company. Effluents were composed of degreasing waters, discharges from the silver and copper adding steps. Certain observations were made: the neutralising pH in the treatment of the degreasing waters was not alkaline enough to precipitate the and the pH was not checked regularly enough. Thirty days after this intervention, the copper concentration showed significant reduction. For mercury, medical activities were investigated, as seen with the Anjou Recherché Case Study and it was discovered that the pollution was mainly due to discharges from two hospitals and one analytical laboratory.

Effectiveness: As the WWTP receives less contaminated wastewater, the manufacturer pays less for the treatment of wastewater. Furthermore, it avoids the cost of landfilling the sludge, as it can then be used in agriculture, decreasing overall costs.

Local Initiatives, Promotion of Environmental Management and Cleaner Production in Denmark.

In Denmark, about 45 industries perform wet treatment of textiles, i.e. pre-treatment, dying, printing and/or after treatment. The majority of these companies are located in the County of Ringkjøbing. This type of business consumes large amounts of water, energy and chemicals.

Impacts: Total consumption of chemicals is approximately 22,000 tonnes per annum (1998), of which approximately 18,000 tonnes per annum consists of basic chemicals (especially salts, acids and bases). The dye stuffs make up approximately 900 tonnes per annum and the residue consists of excipients such as detergents, phthalates etc. The wastewater from wet treatment is typically heavily dyed and has large contents of salt, detergents, post-treatment agents and other chemicals. The total amount of wastewater within this business makes up 6.6 billion cubic metres per annum. Most of the dye works discharge the wastewater at the municipal WWTPs but there are 4 dye works which have their own water treatment plants with a subsequent discharge to recipient waters. (Genbrug af procesvand fra reaktivfarvning af bomuld, Miljøprojekt nr. 374 1998, p. 15. Miljø- og Energiministeriet)

Measure: The County of Ringkjøbing, in close collaboration local authorities and the Federation of Danish Textile and Clothing Industries set up a working party to launch and co- ordinate evaluation of chemicals used in the textile dye process. This working party established a score system to govern chemicals. The score system is based on four

108 5. Review of EU and national measures to reduce the potentially toxic elements and organic pollutants content in wastewater and sewage sludge parameters. Parameter A represents the estimated amount of the chemicals discharged into the environment as wastewater. Parameter B is a score on biodegradability, C is a score on , and D is a score on . Importantly, a lack of information about a certain product will automatically result in a high score. The score system was implemented in 1992-1993 and the dye works in the County of Ringkjøbing undertook to inform the supervisory authorities about their consumption of chemicals according to the score system.

The reporting system allows both administrators and company managers to select priority chemicals and subject them to close examination, on the basis of information filled in the chemical supplier’s specification sheets. For example, in "Egetæpper a/s" a company which dyes and manufactures tufted carpets produces an annual score report. This report is used by the company and the local environmental authorities scope environmental problems, analyze the consumption patterns, and to find opportunities for product substitution and cleaner production technologies. In particular, the company's purchasing policy requires an environmental impact assessment , including the score allotted, before products are bought..

Impacts: The number of products with a high score used in the production at Egetæpper a/s has been reduced considerably between 1992 and 1997. This is partly because some of the products are no longer used by the company and partly because huge efforts have been made in order to procure missing data on the effects these products have on the environment. Egetæpper a/s' environmental report from 1995, the consumption of dye stuffs and excipients has been listed and in this report it is stated that:

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5.5 Education and Information

Education and Information Campaigns can be general or specific, comprising public education campaigns and specific labelling initiatives. The first example is a general information campaign addressing discharges to water the impact of which is difficult to assess. The second is a consumer information campaign that seeks to promote product substitution. The third is both an incentive and an information measure in the form of a prize for effective environmental performance.

Provision of Consumer Information in France

Measure: Centre d’Information sur l’Eau based in Paris launched a campaign to alert people to the problems caused by disposing of compounds down the sink or the toilet. In order to do so, they distribute a leaflet where they note that the following substances should not be disposed of into UWW which include;

· leftover weed killers or fertilisers · out of date or opened medicines · car oils · hydrocarbons · leftover paint or varnish · pesticides and other protecting products

The leaflet also stresses that collection systems are in place in many areas and that information about these is available, and that using a waste disposal unit when connected to the UWW collecting system is prohibited, as is discharging rainwater from gutters into the UWW collecting systems when a separate system is in place in the area. The centre had over 7000 enquiries in 1998.

Eco-labeling and LAS in Scandinavia

Measure: Eco-labeling. Initiatives such the ‘Nordic Swan’ and ‘Good Environmental Choice’- were developed by the Swedish Society for (SSNC) and the Danish Society for the Conservation of Nature (DSCN) respectively. These were aimed at phasing out undesirable chemicals in washing powders and have significantly reduced the use of p LAS (Linear Alkyl Benzene Sulphonate), and Nonylphenol. Eco-labelling campaigns were launched by both the SSNC and DSCN, against washing powders containing LAS, whilst at the same time promoting the use of ‘Swan’ or ‘Good Environmental Choice’ labelled washing powders. In the past decade, the eco-label ‘Good Environmental Choice’ has become one of SSNC most important tools for dealing with environmental problems. The initial campaign was launched in 1988 with the publication of one of many green consumer guides, which included information about chemicals - some of which were found to be replaceable with more suitable alternatives.

Use: LAS is the most important surfactant used in Europe and is found in considerable quantities in washing powders (up to 50%). Some 300000 tonnes of LAS were sold in Europe in 1999, but concerns for its environmental threat have risen since LAS is toxic to aquatic animals and plants. LAS is only degradable in the presence of oxygen, which is not always present in wastewater treatment plants. In addition, it is estimated that about 15-20% of the amount of LAS entering a water treatment plant ends up in sludge with no further degradation (S. Hagenfors, 2000).

Effectiveness: Products which do not contain LAS or Nonylphenol and have gained considerable market share since the launch of the campaign. “In Sweden, products with this label accounted for 95% of sales by 1997 and consumer choice lead to a decline in use of

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LAS from 6,300 tonnes per year to 260 tonnes per year” (Danish Environmental Agency 2000). The published guide was a success and prompted consumers to demand for more detailed information about domestic products and their potential environmental impact. Coincidentally one the main in the region at the time was that of widespread of Scandinavian water bodies which subsequently induced a demand by consumers for environmentally friendly products. In brief, public awareness made the market for eco-labelled products grow in Sweden, so that after the first manufacturer (Unilever) launched its eco-labelled detergent, other multi-nationals had to follow.

In Sweden, eco-labelling has however been limited in terms of product range and multi- national manufacturers have not introduced other eco-labelled products, with the exception of a few minor producers that specialise in ‘green’ products. In other Scandinavian countries, the market share of ‘Swan’ products is significantly smaller, with 15% in Finland and less in Norway and Denmark; the difference in share thought to be due to less public awareness campaigning. Yet, in the last ten years, the Swedish market for eco-labelled products has undergone important modifications. It is estimated that presently 60% of the chemical ingredients in soap, shampoo, detergents have been substituted or removed, the remaining 40% of chemicals falling within the list of substances approved by the ‘Swan’ and ‘Good Environmental Choice’ guidelines. The 38000 tons of chemicals subject to substitution have been replaced by 29000 tons of approved substances, the difference (9000 tons) having been removed. The substitute chemicals are all approved by eco-labels and are more biodegradable in plants and sludge, meaning less environmental risk and less treatment costs. As a result, it is estimated that the use of LAS in Sweden has been reduced by 95% (S. Hagenfors, 2000).

In addition, the development of the eco-label ‘Swan’ has prompted Stockholm Water Co. to initiate a plan for the identification of measures to reduce hazardous household wastes being flushed down the drain and into WWTP. This lead to the establishment of ‘environmental stations’ or collection points and to the launch of a thorough public awareness and information campaign about the impacts of household products on the aquatic environment

Awards for Company Innovation in Waste Management and Minimisation

In 1996, the trophy ADEME "Economic and clean technologies" went to the STEN society, which is a finishing company which managed zero cadmium discharges by concentrating the cadmium-containing effluents through evaporation and recovered the metal through electrolysis [ADEME, 1997].

5.6 Conclusion

The review of National Practices with respect to UWW demonstrated a range of problems, and identified some strategies for dealing with diffuse and small-scale sources of .

Without upstream control, UWW treatment cannot treat all wastewater pollutants, resulting in effluent and sludge quality problems. A range of measures are likely to be most effective in mitigating problems, and the appropriate policy mix will vary according to the pollutant, industry structure, local conditions and social factors, and there should be room for local discretion.

Product Bans in particular may be appropriate where product substitution is a possibility. Economic Instruments such as taxes and charges can, if carefully designed and targeted, provide appropriate incentives for alternative approaches by industry and producers of waste. Where the costs of treatment are transparent, it is more likely that least cost

111 5. Review of EU and national measures to reduce the potentially toxic elements and organic pollutants content in wastewater and sewage sludge alternatives will be pursued through the use of subsidies to waste reduction or collection. Targeted Voluntary and Educational Initiatives may assist but the full costs and benefits of specific instruments are difficult to assess.

Full Cost Recovery for Waste and Water Services (under the Water Framework Directive) will assist in making the costs of dealing with particular pollutants more transparent. Nevertheless, the use of economic and alternative instruments and strategies should be recognized as the legally appropriate implementation measures in both EU and National Legislation, and the competent authorities should be legally empowered to establish and participate in alternative measures, including substitution and recovery schemes.

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