Stewardship Framework Legislation and any subordinate regulatory instruments.”

Disposal

demand. disassembling EOL • Lack of practices stock. understanding of the requirements DIIS Section 7 • In the event of Insufficient funds • Lack of regulation Section 7.2 – Insurance requires Strong Unlikely Modera Mediu Maintain an available in the event • Operator goes out recyclers to have a documented te m existing environmental of major pollutant of business closure plan that assures proper controls incident, the cost releases, closure of the facility in the event of cleanup would mismanagement or of business failure or shutdown to be borne by closure of the facility. ensure the avoidance of any government abandonment of EOL products, components or materials. The closure plan must be supported by proof of a sufficient financial instrument to guarantee the execution of the closure plan. DIIS – Section 7.4 • Injury to Failure to ensure • Unlicensed Appendix 5 of the DIIS provides a Incomplet Possible Modera Mediu Completion employees staff are provided operator checklist of requirements for e te m of checklist with necessary • Lack of employees working in the facilities. should be personal protective understanding of This checklist includes provision mandatory equipment. OH&S risks and correct use of any personal and protective equipment included in the body of the Standard. Risk Identification and Assessment 82 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) DIIS – Section 7.4 • Workplace Mechanical material • Materials Section 7.4 – Processing and Maintain becomes processing and deposited at an Handling dictates the equipment existing hazardous to separation facilities Inappropriate required to be installed at the controls employees are not properly facility recycling facility. This includes a Strong Possible Modera Mediu equipped with dust • Operator fails to dust collection system, an te m collection and other adhere to emergency shut off system, environmental regulatory adequate fire suppression control measures requirements equipment and other such as air emission • Regulatory safety/environmental control control systems. requirements not equipment identified in the plan enforced arising from the risk assessment. Requirements for • Fire causing Risk of fire resulting • Failure to identify Section 7.4 – Processing and Recyclers Adequate Possible Major High Refer to risk damage to life from failure to presence of Handling requires the removal of treatment and property remove batteries batteries components, prior to processing, DIIS – Appendix 1 plan from motherboards • Inexperienced likely to pose a health and safety prior to shredding. operator fails to risk. This section of the DIIS remove batteries requires as a minimum the removal of; • Mecury bearing lamps • Ink and toner cartridges • Batteries • CRT and flat panel displays. Reuse • Contaminated Inappropriate • Incorrect Appendix 1 – Cathode Ray Tube, Applications Incomplet Possible Modera Mediu Information product used as secondary classification of contained in Leaded Plasma Display Glass and e te m virgin material application of material Appendix 1 Other Leaded Glass, identifies non- Risk Identification and Assessment 83 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) DIIS – Appendix 1 recovered resources • Contaminated substitute environmentally sound reuse needs to be eg: use of leaded product sent for applications and recommends more glass from plasma reuse/ secondary avoiding these practices. prescriptive screens as a application and included substitute for sand. in the body of the Standard. • Unnecessary (Consolidated Lack of minimum • No requirement to Table 1 – Material Processing and Incomplet Possible Modera Mediu Formal disposal of EOL Stakeholder recycling rate or achieve a End Use Acceptability specifies e te m developme product to Comments - requirement for minimum level of recycling processing, end-use, or nt and landfill due to response to Q1.) highest use practices, recycling method of disposal. Where adoption of lack of incentive in the DIIS components are and materials are PSO to divert discourages recyclers deemed to be recoverable, Landfill procuremen maximum from recovering or incineration are “not t volume possible. materials leading to acceptable” as disposal options. specificatio unnecessary disposal ns to ensure The Drafting note adjacent to to landfill. adoption of Section 7.5 Traceability, states that recovery international developments will and continue to be monitored in this recycling area and recovery and recycling rates rates will be specified in the Product Stewardship Organisation procurement specifications. They will be based on the agreed National Television and Computer Scheme KPIs and available technology. Risk Identification and Assessment 84 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) (Consolidated Failure to minimise • Lack of knowledge • Increased carbon Section 3-of the DIIS Guiding Incomplet Likely Modera High Refer to Stakeholder carbon emissions regarding carbon emissions Principles requires decisions about e te Risk Comments – associated with emissions from treatment of EOL Televisions and Treatment response to Q1.) recycling practices. associated Computers to consider the waste Plan recycling practices management hierarchy and the and LCA results in principles of ecologically more damage to sustainable development including the environment. minimising carbon emissions. • Environmental (Consolidated Failure of the DIIS to No regulatory Appendix 1 of the DIIS provides Weak Possible Modera Mediu Guidelines damage Stakeholder require identification requirement guidance on the environmentally • Potential safety te m should be Comments – of hazardous Recyclers sound recycling of electronics. more risk to staff response to Q1.) substances prior to unknowingly prescriptive disposal. process EOL and become product formal containing requiremen local areas for local structure to establishme practices. waste treatment ( encourage new nt of esp. in rural areas.) players into the sufficient market facilities. Risk Identification and Assessment 87 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) (Consolidated • Lack of facilities Failure to accredit • Lack of Stakeholder None in Likely Minor Mediu Establish to cope with sufficient number of government place Comments - m sufficient demand leads to operators/ locations support feedback to Q4.) infrastructu below optimum to meet demands • Ineffective funding re to meet leads to disposal at structure to demand. practices. inappropriate encourage new facilities players into the market • Identified POPs (Consolidated Failure of the DIIS to • Lack of Appendix 2 of the DIIS identifies Incomplet Likely Modera High Refer to risk remain in the Stakeholder address the 9 new regulation/guidan Australia’s obligations under the e te treatment waste stream Comments - POPs identified under ce from Stockholm Convention on plan with potential to response to Q5.) the Stockholm government. Persistent Organic Pollutants. This cause severe Convention Of the nine section also refers to the nine new environmental new POPs, chemicals added to the damage the ones Convention’s Annexes. • Australia fails to with maintain its implications obligations under for recycling the Stockholm are the Convention BFRs. The other chemicals aren’t particularly relevant in the context of plastic recycling - Risk Identification and Assessment 88 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) Appendix 2 could be improved to explain this. (Consolidated Failure to separate • Failure to adhere • Contaminated The “Notes” to accompany Table 1 Stakeholder Developme substances of to regulatory waste is disposed Material Processing and End Use Comments - nt and Incomplet concern for integrity Possible Modera requirements Mediu of at an Acceptability, the DIIS states that Feedback to Q5.) adoption of e and traceability. te m unlicensed or Draft European standards such as prescriptive inappropriate Weelabex define acceptable levels guidelines facility of particular BFRs in end of waste when plastic. In addition the Australian commerciall Government is monitoring the y viable work of the scientific committee separation established under the Stockholm methods convention to develop guidance are materials on how to tackle issues available. such as identification of waste articles that contain BFRs, procedures for detection and separation, issues associated with recycling and appropriate methods of destruction. Industry‘s intention is that as soon as commercially viable separation methods are available and further guidance materials are available these will be adopted either in the interim industry standard or in the Risk Identification and Assessment 89 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) broader Australian Standard under development. Section 7.4 also requires “Substances of Concern” to be kept separate to ensure integrity and traceability of the material stream. Transport • International Export to non OECD • Lack of Table 1 – Material Processing and Requirements Adequate Unlikely Major High Refer to risk embarrassment countries without the regulation/auditin End Use Acceptability, states treatment and penalties appropriate permit g of operations “exporting to non-OECD countries (Consolidated plan under the Hazardous for the purpose of recycling and/or Stakeholder Waste Act disposal without the appropriate Comments - permit under the Hazardous Waste Additional Issues) Act,” is not acceptable for specified materials. (Consolidated • Failure to Lack of baseline data • No industry Section 4.1 (d) Risk Management Adequate Stakeholder Unlikely Modera Mediu identify for exposure to guidelines requires monitoring of worker Comments - te m hazardous levels hazardous exposure or air emissions if response to Q2.) of toxic substances. potential exposure above the safe substances exposure limits or potential for emissions to atmosphere have been identified as a potential risk. Risk Identification and Assessment 90 Regulatory Risk Review Appendix E – Regulatory Risk Review 91 Table 9: Regulatory Risk Review Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) Legal Compliance Hazardous Waste (Regulation of Exports and Imports) Act 1989 (Part4) • Conviction Export • Permit not Section 2 of the standard – Adequate Unlik Majo Hig Refer to hazardous obtained Regulation Application – includes the ely r h Risk waste without • Order to export of export following control: treatment permit to of not given “The Interim industry Standard plan. hazardous export or order does not absolve collection waste to export locations, transporters or recyclers from any federal, state and/or municipal legislation and regulations applicable to their business operation. It is the responsibility of the operator to be aware of and abide by all such legislation and regulations.” Section 40AA • Conviction Sell waste to • No due diligence Section 2 of the standard – Adequate Unlik Majo Hig Refer to body corporate undertaken Regulation Application – includes the ely r h Risk outside • Permit not of sale of following control: treatment Australia hazardous obtained “The Interim industry Standard plan waste where the body does not absolve collection corporate does locations, transporters or not have a recyclers from any federal, state Regulatory Risk Review 92 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) registered and/or municipal legislation and office and an regulations applicable to their executive in business operation. It is the Australia; and responsibility of the operator to knowing the be aware of and abide by all such waste will be legislation and regulations.” exported by the body corporate (or is reckless as to whether knowing);and export permit not in force at time of sale. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal Article 4(b) • Contravention Parties shall • Prohibited waste Compliance with Section 40A of Adequate Unlik Majo Hig Refer to of Basel prohibit or exported the Hazardous Waste (Regulation ely r h Risk Convention shall not of Exports and Imports) Act 1989 treatment permit the plan export of hazardous wastes and other wastes to the Parties which have Regulatory Risk Review 93 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) prohibited the import of such wastes Article 6 • Contravention The State of • Waste exported Compliance with Section 40A of Adequate Unlik Majo Hig Refer to of Basel export shall not prior to receiving the Hazardous Waste (Regulation Transbounda ely r h Risk Convention allow the written consent of Exports and Imports) Act 1989 ry treatment generator or Movement plan exporter to between commence the Parties transboundary movement until it has received written confirmation that: (a) The notifier has received the written consent of the State of import; and (b) The notifier has received from the State of import Regulatory Risk Review 94 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) confirmation of the existence of a contract between the exporter and the disposer specifying environmentall y sound management of the wastes in question. Article 9 • Contravention For the • Consent not Compliance with Section 40A of Adequate Unlik Majo Hig Refer to of Basel purpose of this obtained; the Hazardous Waste (Regulation Illegal Traffic ely r h Risk Convention Convention, • Falsification of of Exports and Imports) Act 1989 treatment any consent plan transboundary • Non-conforming movement of consent hazardous • wastes or other contravenes wastes: intent of Basel (a) without convention notification pursuant to the provisions of this Convention to all States Regulatory Risk Review 95 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) concerned; or (b) without the consent pursuant to the provisions of this Convention of a State concerned; or (c) with consent obtained from States concerned through falsification, misrepresentat ion or fraud; or (d) that does not conform in a material way with the documents; or (e) that results in deliberate disposal (e.g. dumping) of Regulatory Risk Review 96 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) hazardous wastes or other wastes in contravention of this Convention and of general principles of international law, shall be deemed to be illegal traffic. Stockholm Convention on POPs Article 3 • Contravention That a • Export not for Where the Stockholm POP is Adequate Measures to Unlik Majo Hig of the Basel and chemical listed environmentally identified as a waste that ely reduce or r h Stockholm in Annex A for sound disposal requires final disposal, then eliminate Conventions which any compliance with Section 40A of releases production or the Hazardous Waste (Regulation from use specific of Exports and Imports) Act 1989 intentional exemption is in is required. production effect or a and use chemical listed in Annex B for Regulatory Risk Review 97 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) which any production or use specific exemption or acceptable purpose is in effect, taking into account any relevant provisions in existing international prior informed consent instruments, is exported only: • Contravention (i) For the • Export not for Compliance with Section 40A of Adequate Unlik Majo Hig of Basel and purpose of environmentally the Hazardous Waste (Regulation ely r h Stockholm environmentall sound disposal of Exports and Imports) Act 1989 Conventions y sound disposal as set forth in paragraph1 (d) of Article 6; • Contravention (ii) To a Party • Export not to Commonwealth Government Inadequate * of Stockholm which is party permitted does not appear to have a direct * Regulatory Risk Review 98 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) permitted to to use the Convention control in place* use that chemical chemical under Annex A or Annex B; or • Contravention (iii) To a State • Export not to Commonwealth Government Inadequate * of Stockholm not Party to party which has does not appear to have a direct * Convention this Convention provided export control in place* which has certification. provided an annual certification to the exporting Party. Such certification shall specify the intended use of the chemical and include a statement that, with respect to that chemical, the importing State is committed to: Regulatory Risk Review 99 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) a. Protect human health and the environment by taking the necessary measures to minimize or prevent releases; b. Comply with the provisions of paragraph 1 of Article 6; and c. Comply, where appropriate, with the provisions of paragraph 2 of Part II of Annex B. • Contravention (c) That a • Export not for Compliance with Section 40A of Adequate Unlik Majo Hig of Basel and chemical listed environmentally the Hazardous Waste (Regulation ely r h Stockholm in Annex A, for sound disposal Regulatory Risk Review 100 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Description of Potential Potential impacts Existing controls Control Likeli- Conse- Risk Further Category risk causes/sources (if a risk event (what is in place NOW to minimise ratings hood quenc Leve Treatment? (What can (of an event happens) e l risk) happen) happening) which Conventions of Exports and Imports) Act 1989 production and use specific exemptions are no longer in effect for any Party, is not exported from it except for the purpose of environmentall y sound disposal as set forth in paragraph 1 (d) of Article 6; * When export of a Stockholm POP involves prior consent for use of the chemical, the Hazardous Waste (Regulation of Exports and Imports) Act 1989 does not apply. Consequently, this risk of the chemical being inappropriately used under the convention (by a party or State not permitted to use the chemical) appears to have no control. This has been flagged as an issue for the Commonwealth Government, but not considered specifically in the Risk Treatment Plan (Appendix F) since it is not a risk that either arises as a direct implication of the DIIS, or applies to parties to the scheme. Regulatory Risk Review 101 Appendix F – Risk Treatment Plan Risk Treatment Plan 102 Table 10: Risk Treatment Plans Risk Category & Description of risk Potential Potential impacts Existing controls Control Likelihood Consequence Risk Level Origin (What can happen) causes/sources (if a risk event happens) (what is in place NOW to minimise risk) ratings (of an event happening) • Potential harm to General Operator fails to • Untrained Section 4.1 of the DIIS requires Adequ possible Moderate High employees and the Requirements develop and operator collection locations, transporters and ate environment as a implement doesn’t recyclers to have documented work (Section 4.1 DIIS) result of unsafe documented work understand the methods describing safe and work practices. methods operational risks environmentally sound practices. describing safe and requirements environmentally • Lack of industry sound practices standard requirement and/or enforcement. Further Treatment: To coincide with the implementation of the DIIS, DSEWPaC in cooperation with the Product Stewardship Organisation, need to implement the auditing regime suggested in the notes attached to Section 2 to monitor compliance of operators. Whilst Section 4.2 Legal Compliance, requires operators to maintain a documented process to identify, assess and ensure compliance with this standard and all applicable regulatory requirements, without a robust monitoring/auditing scheme in place and an accompanying timetable, the risk of harm to an employee and/or the environment remains high. The development and rollout of a familiarisation/training program for operators is also recommended to provide detailed information on the specific reporting requirements of the Standard. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: PSO under the approved arrangement. It should be noted that this risk is likely to remain “High” as there is always the possibility that this may occur and the consequences would remain at least “moderate.” Risk Treatment Plan 103 Risk Category & Description of risk Potential Potential impacts Existing controls Control Likelihood Consequence Risk Level Origin (What can happen) causes/sources (if a risk event happens) (what is in place NOW to minimise ratings (of an event risk) happening) • International Export to non Lack of Table 1 – Material Processing Adequa Unlikely Major High embarrassment and Transport OECD countries regulation/a and End Use Acceptability, te penalties Requirements without the uditing of states “exporting to non-OECD appropriate operations countries for the purpose of (Consolidated permit under the recycling and/or disposal Stakeholder Hazardous Waste without the appropriate permit Comments - Act under the Hazardous Waste Additional Issues) Act,” is not acceptable for specified materials. Further Treatment This risk has rated as “High” primarily due to the potential consequence should the risk occur. The Hazardous Waste Act 1989 conveys Australia’s obligations with the exporting of waste and the requirements of the Act are again reiterated in the DIIS. Associated risks have also been identified in the Regulatory Risk review included in Section 3.3.1. To further mitigate this risk, the requirements of the Hazardous Waste Act 1989 and how they apply to DIIS associated activities could also be included in the proposed training/familiarisation program suggested as an improvement measure in the risk treatment plan above. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: PSO under the approved arrangement. It should be noted that this risk is likely to remain “High” as the consequence will always be major. Risk Treatment Plan 104 Risk Category & Description of Potential Potential impacts Existing controls Control Likelihood Consequence Risk Level Origin risk causes/sources (if a risk event happens) (what is in place NOW to minimise risk) ratings (What can (of an event happen) happening) • Fire causing Risk of fire Failure to Section 7.4 – Processing and Adequat Possible Major High damage to life and Requirements for resulting from identify Handling requires the removal of e property Recyclers failure to presence of components, prior to processing, remove batteries likely to pose a health and safety batteries from • Inexperienced risk. This section of the DIIS requires motherboards operator fails to as a minimum the removal of; prior to remove • Mercury bearing lamps shredding. batteries • Ink and toner cartridges • Batteries • CRT and flat panel displays. Further Treatment Section 7.4 of the DIIS already requires the safe removal of components prior to processing. This risk is more likely to occur in facilities that are not experienced in appropriate materials separation and handling. Training and familiarisation for all “accredited” operators is recommended to coincide with the implementation of the DIIS and ensure the associated risks are fully understood. In addition all disassembly facilities should be fitted with appropriate early smoke detection equipment, and other suitable fire retardant equipment. Appendix 1 of the DIIS provides guidance on the environmentally sound removal of electronics however this is an extract from the Canadian Standard. In order to strengthen the requirement of the Standard in relation to this issue it is recommended that the contents of Appendix 1 become more prescriptive or included in the body of the Standard rather simply referred to in the risk management section. The introductory comments of Appendix 1 state the guidance document was developed to serve as an educational document. It would therefore be useful to ensure the contents are included into a training session for delivery to operators as outlined in the risk treatment plans above. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: PSO under the approved arrangement. It should be noted that this risk is likely to remain “high” as the consequence will always be major. Risk Treatment Plan 105 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control ratings Likelihood Consequ Risk Level Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise risk) ence happens) • Workplace Employees are Materials deposited at Section 7.4 – Processing and Handling Adequate Unlikely Major High becomes Requirements for exposed to an Inappropriate facility requires the removal of components, hazardous Recyclers mercury • Operator fails to adhere prior to processing, likely to pose a to contamination to regulatory operating health and safety risk. This section of employees due to failure to requirements the DIIS requires as a minimum the remove lamps and • Regulatory requirements removal of; bulbs prior to not enforced • Mercury bearing lamps shredding or • Ink and toner cartridges mechanical • Batteries processing • CRT and flat panel displays. Further Treatment To coincide with the implementation of the DIIS, the approved arrangement needs to implement the auditing regime suggested in the notes attached to Section 2 to monitor compliance of operators. Whilst Section 4.2 Legal Compliance, requires operators to maintain a documented process to identify, assess and ensure compliance with this standard and all applicable regulatory requirements, without a robust monitoring/auditing scheme in place and an accompanying timetable, the risk of harm to an employee and/or the environment remains high. Section 7.4 of the DIIS already requires the safe removal of components prior to processing. This risk is more likely to occur in facilities that are not experienced in appropriate materials separation and handling. Training and familiarisation for all “accredited” operators is recommended to coincide with the implementation of the DIIS and ensure the associated risks are fully understood. In addition all disassembly facilities should be fitted with appropriate extraction and filtration equipment and PPE for all employees. Appendix 1 of the DIIS provides guidance on the environmentally sound removal of electronics however this is an extract from the Canadian Standard. In order to strengthen the requirement of the Standard in relation to this issue it is recommended that the contents of Appendix 1 become more prescriptive or included in the body of the Standard rather simply referred to in the risk management section. The introductory comments of Appendix 1 state the guidance document was developed to serve as an educational document. It would therefore be useful to ensure the contents are included into a training session for delivery to operators as outlined in the risk treatment plans above. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: The approved arrangement. It should be noted that this risk is likely to remain “High” as the consequence will always be major. Risk Treatment Plan 106 Risk Category & Description of risk Potential Potential impacts Existing controls Control ratings Likelihood Consequence Risk Level Origin (What can happen) causes/sources (if a risk event happens) (what is in place NOW to (of an event minimise risk) happening) • Increased carbon (Consolidated Failure to Lack of Section 3-of the DIIS Incomplete Likely Moderate High emissions Stakeholder minimise carbon knowledge Guiding Principles requires Comments – emissions regarding decisions about treatment response to Q1.) associated with carbon of EOL Televisions and recycling emissions Computers to consider the practices due to from waste management insufficient associated hierarchy and the principles knowledge recycling of ecologically sustainable around LCA. practices development including results in minimising carbon more emissions. damage to the environment. Further Treatment The Standard needs to adopt a more prescriptive approach and/or access to more detailed information to inform operators on ecologically sustainable practices to ensure carbon emissions from associated practices are minimised. Currently, Section 3 “Guiding Principles” provide nothing but a cursory reference to carbon emissions and no further guidance on how best to ensure emissions are minimised. It would be acceptable to adopt existing guidelines or principles that provide detail on how to manage associated carbon however this Standard needs to clearly state that it requires operators to adhere to/implement whatever additional documents it chooses to adopt. Timeframe for Implementation: Prior to release of the Standard. Responsibility: DSEWPaC By implementing the suggested improvements the likelihood of this risk occurring would drop to possible thus reducing the overall rating to Moderate. Risk Treatment Plan 107 Risk Category & Description of risk Potential Potential impacts Existing controls Control ratings Likelihood Consequence Risk Level Origin (What can happen) causes/sources (if a risk event (what is in place NOW to (of an event happens) minimise risk) happening) • Identified POPs (Consolidated Failure of the DIIS Lack of Appendix 2 of the DIIS Incomplete Likely Moderate High remain in the Stakeholder to address the 9 regulation/g identifies Australia’s waste stream Comments – new POPs uidance obligations under the with potential NGO response identified under from Stockholm Convention to cause severe to Q5.) the Stockholm government on Persistent Organic environmental Convention . Pollutants. This section damage also refers to the nine • Australia fails to new chemicals added maintain its to the Convention’s obligations Annexes. under the Stockholm Convention Further Treatment Of the 9 new POPs, the ones with implications for recycling are the BFRs. The other chemicals aren’t particularly relevant in the context of plastic recycling - Appendix 2 could be improved to explain this. Timeframe for Implementation: Prior to release of the Standard. Responsibility: DSEWPaC Risk Treatment Plan 108 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control ratings Likelihood Consequ Risk Level Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise risk) ence happens) Export hazardous • Permit not obtained Conviction Section 2 of the standard – Adequate Unlikely Major High waste without Regulation of • Order to export not Application – includes the following permit to export export of given control: hazardous or order to export “The Interim industry Standard does waste not absolve collection locations, transporters or recyclers from any federal, state and/or municipal legislation and regulations applicable to their business operation. It is the responsibility of the operator to be aware of and abide by all such legislation and regulations.” Further Treatment To ensure transporters and operators are fully aware of their regulatory requirements relating to the export of hazardous waste, it is recommended that the requirements of the Hazardous Waste Act and how they apply to DIIS associated activities are included in the proposed training/familiarisation program suggested as an improvement measure in the risk treatment plan above. The approved arrangement should ensure that DSEWPaC is consulted in relation to all training material and provided the opportunity to participate. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: DSEWPaC It should be noted that this risk is likely to remain “high” as the consequence will always be major. Risk Treatment Plan 109 Risk Category Description of risk Potential causes/sources Potential impacts Existing controls Control ratings Likeli- Conse- Risk Level (What can happen) (of an event happening) (if a risk event hood quence (what is in place NOW to minimise risk) happens) Section 40AA • Conviction Sell waste to body • No due diligence Section 2 of the standard – Adequate Unlikely Major High corporate outside Regulation of undertaken Application – includes the following Australia where sale of • Permit not obtained control: hazardous the body “The Interim industry Standard does waste corporate does not absolve collection locations, not have a transporters or recyclers from any registered office federal, state and/or municipal and an executive legislation and regulations applicable in Australia; and to their business operation. It is the knowing the responsibility of the operator to be waste will be aware of and abide by all such exported by the legislation and regulations.” body corporate (or is reckless as to whether knowing);and export permit not in force at time of sale. Further Treatment To ensure transporters and operators are fully aware of their regulatory requirements relating to the sale of hazardous waste, it is recommended that the requirements of the Hazardous Waste Act and how they apply to DIIS associated activities are included in the proposed training/familiarisation program suggested as an improvement measure in the risk treatment plan above. The approved arrangement should ensure that DSEWPaC is consulted in relation to all training material and provided the opportunity to participate. In addition DSEWPaC could provide guidance on the necessary due diligence required to ensure a breach does not occur. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: DSEWPaC It should be noted that this risk is likely to remain “high” as the consequence will always be major. Risk Treatment Plan 110 Risk Category Description of risk Potential causes/sources Potential impacts Existing controls Control ratings Likeli- Conse- Risk Level (What can happen) (of an event happening) (if a risk event hood quence (what is in place NOW to minimise risk) happens) Basel Parties shall • Contravent Compliance with Section 40A of the Adequate Unlikely Major High Prohibited waste Convention prohibit or shall exported ion of Basel Hazardous Waste (Regulation of Article 4(b) Convention not permit the Exports and Imports) Act 1989 export of hazardous wastes and other wastes to the Parties which have prohibited the import of such wastes Further Treatment To ensure transporters and operators do not contravene Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal it is recommended that the requirements of the Hazardous Waste Act and the Basel Convention are included in the proposed training/familiarisation program suggested as an improvement measure in the risk treatment plan above. The approved arrangement should ensure that DSEWPaC is consulted in relation to all training material and provided the opportunity to participate. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: DSEWPaC and the approved arrangement. It should be noted that this risk is likely to remain “high” as the consequence will always be major. Risk Treatment Plan 111 Risk Category Description of risk Potential Potential impacts Existing controls Control ratings Likeli- Conse- Risk Level (What can happen) causes/sources (if a risk event hood quence (what is in place NOW to minimise risk) (of an event happens) happening) Basel Convention • Contravent The State of export shall • Waste Compliance with Section 40A of the Adequate Unlikely Major High ion of Basel not allow the generator or exported prior Hazardous Waste (Regulation of Article 6 Convention exporter to commence the to receiving Exports and Imports) Act 1989 transboundary movement written Transboundary until it has received written consent Movement confirmation that: between Parties (a) The notifier has received the written consent of the State of import; and (b) The notifier has received from the State of import confirmation of the existence of a contract between the exporter and the disposer specifying environmentally sound management of the wastes in question. Further Treatment To ensure transporters and operators do not contravene Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal it is recommended that the requirements of the Hazardous Waste Act 1989 and the Basel Convention are included in the proposed training/familiarisation program suggested as an improvement measure in the risk treatment plan above. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: DSEWPaC and the approved arrangement. It should be noted that this risk is likely to remain “high” as the consequence will always be major. Risk Treatment Plan 112 Risk Description of risk Potential Potential impacts Existing controls Control Likeli- Conse- Risk Level Category (What can happen) causes/sources (if a risk event (what is in place NOW ratings hood quence (of an event happens) to minimise risk) happening) Basel • Contravention For the purpose of this Convention, any • Consent not Compliance with Convention Adequate Unlikely Major High of Basel transboundary movement of hazardous wastes or obtained; Section 40A of the Convention other wastes: • Falsification Hazardous Waste Article 9 of consent (a) without notification pursuant to the provisions of (Regulation of Illegal this Convention to all States concerned; or • Non- Exports and Imports) Traffic conforming Act 1989 (b) without the consent pursuant to the provisions of consent this Convention of a State concerned; or • Disposal (c) with consent obtained from States concerned contravenes through falsification, misrepresentation or fraud; or intent of Basel (d) that does not conform in a material way with the convention documents; or (e) that results in deliberate disposal (e.g. dumping) of hazardous wastes or other wastes in contravention of this Convention and of general principles of international law, shall be deemed to be illegal traffic. Further Treatment To ensure transporters and operators do not contravene Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal it is recommended that the requirements of the Hazardous Waste Act and the Basel Convention are included in the proposed training/familiarisation program suggested as an improvement measure in the risk treatment plan above. Timeframe for Implementation: To coincide with the implementation of the Standard. Responsibility: DSEWPaC It should be noted that this risk is likely to remain “high” as the consequence will always be major. Risk Treatment Plan 113 Risk Category Description of risk Potential Potential impacts Existing controls Control Likeli- Conse- Risk Level (What can happen) causes/sources (if a risk event happens) ratings hood quence (what is in place (of an event NOW to minimise happening) risk) Stockholm That a chemical listed in Annex A for which • Export not for • Contravention of Compliance with Convention Adequate Unlikely Major High any production or use specific exemption is in environmentally Basel and Section 40A of the effect or a chemical listed in Annex B for sound disposal Stockholm Hazardous Waste Article 3 which any production or use specific Conventions (Regulation of Measures to exemption or acceptable purpose is in effect, Exports and reduce or taking into account any relevant provisions in Imports) Act 1989 eliminate existing international prior informed consent releases from instruments, is exported only: intentional production (i) For the purpose of environmentally sound and use disposal as set forth in paragraph1 (d) of Article 6; • Contravention of (c) That a chemical listed in Annex A, for • Export not for Compliance with Adequate Unlikely Major High Basel and which production and use specific exemptions

Hazardous Ingredients

t of industry operators/ recyclers. • Environmental (Consolidated Brominated Fire • Lack of knowledge Appendix 1 of the DIIS provides Incomplet Possible Modera Mediu Guidelines damage Stakeholder Retardant that BFR is present guidance on the environmentally e te m should be Comments – contaminated • Poor separation sound recycling of electronics and more response to Q1.) plastics are sent to practises result in specifically identifies Brominated prescriptive landfill. cross Fire Retardant as a “substance of and become Risk Identification and Assessment 85 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) contamination concern” when addressing plastics requiremen with BFR. recovery. t of industry operators/ recyclers. • Failure to (Consolidated Failure of the DIIS to • Lack of regulatory Table 1 – Material Processing and Adequate Possible Minor Mediu Implementa recover Stakeholder require recycling of controls End Use Acceptability advises that m tion of recyclable Comments – associated packaging • Cost of recovery recoverable packaging materials Standard resources response to Q1.) waste. versus disposal must be recovered and requiremen leading to reprocessed where possible. Land t and increase in waste filling of recyclable material is no auditing to to landfill acceptable. ensure compliance. • Unauthorised ((Consolidated Failure of the DIIS to • Lack of regulatory Section 7 of the DIIS Requirements Possible Modera Mediu Recovery operators set up Stakeholder accurately define the controls/definition for Recyclers identifies the te m and and carry out Comments – role of recyclers Incomplet s operational requirements for recycling business in an response to Q2.) results in e recyclers. rates need unsafe and uncontrolled to be potentially Section 8 – Definitions provides a practices. developed damaging definition for “Recycler” and and agreed manner. “recycling.” upon as per the drafting note included under Section 7.5. Risk Identification and Assessment 86 Part A - Risk Identification and analysis 1 2 3 4 5 6 7 8 9 10 Risk Category & Description of risk Potential causes/sources Potential impacts Existing controls Control Likeli- Conse- Risk Further Origin (What can happen) (of an event happening) (if a risk event (what is in place NOW to minimise ratings hood quence Level Treatment? happens) risk) (Consolidated • Employees are Failure of recycling • Lack of knowledge Section 7.4 – Processing and Stakeholder Strong Unlikely Modera Mediu Maintain unnecessarily facilities to document • Lack of formal Handling dictates the equipment Comments - te m existing exposed to safe exposure limits procedures in required to be installed at the response to Q2.) controls airborne toxins for airborne toxins place recycling facility. This section also including lead, toner • Lack of regulatory requires recyclers to undertake dust, silica, beryllium requirement monitoring of air quality and noise etc and Noise levels. levels. (Consolidated Use of charity/ • Lack of knowledge • Unsafe work Section 4.1 (b) of the DIIS requires Stakeholder Adequate Possible Modera Mediu Implementa disability labour and • Lack of formal practices lead to management to conduct training Comments - te m tion of failure to provide a procedures in employee harm and assessment of all people response to Q3.) auditing safe work place (regardless of ability) involved in regime environment and • Staff ability carrying out the identified training on activities. appropriate work practices. • Lack of facilities (Consolidated Lack of • Lack of None in Likely Minor Mediu Provision of to cope with Stakeholder encouragement for government place m government demand leads to Comments – job creation/industry support support to below optimum response to Q4.) establishment in • Ineffective funding ensure