EiMAS Training Material

Course Title: Certified Environmental Professional in Schedule Waste Management

Module 1: Overview

MODULE OVERVIEW

Course Title: Course for Certified Environmental Professional in

Schedule Waste Management

Course CePSWaM
Abbreviation:

Module Title: Overview on Scheduled Waste Management

Module No.: 1

Objectives: The participants will be able to :

 understand the concept cradle to grave
 understand waste management hierarchy
 identify and classify scheduled wastes
 describe the major classifications
 describe the scheduled wastes which may be
associated with the waste classifications in the
Malaysian waste codes

Contents: TEXT: pages

Duration: 2 hours

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 0
TOC

TABLE OF CONTENTS

1.0 INTRODUCTION TO MODULE 1 ...............................................................1

1.1 INTRODUCTION .........................................................................................2
1.1.1 Purpose .......................................................................................2

1.2 SCHEDULED WASTE MANAGEMENT......................................................2

1.2.1 Scheduled Waste Management in Malaysia…………………….2

1.3 PRINCIPLE OF CRADLE TO GRAVE………………………………………...6

1.4 SCHEDULED WASTES MANAGEMENT HIERARCHY…………………….9

1.5 IDENTIFICATION AND CLASSIFICATION OF SCHEDULED
WASTES .....................................................................................................10
1.5.1 What is meant by Identification and Classification?...............10
1.6 LEGISLATIVE BACKGROUND FOR CLASSIFICATION OF SCHEDULED
WASTE……………………………………………………………………………11
1.6.1 Introduction.................................................................................11
1.6.2 Definition of Waste .....................................................................12
1.6.3 Definition of Scheduled Wastes ................................................12
1.7 IDENTIFICATION OF SCHEDULED WASTES…………………..................14
1.7.1 Introduction.................................................................................14
1.7.2 Identifiable Non-Scheduled Waste............................................15
1.7.3 Source of the Waste ...................................................................15
1.7.4 Basic Physical and Chemistry Character of The Waste..........15
1.7.5 What Do Scheduled Wastes Look Like? ..................................18
1.8 HAZARDOUS SUBSTANCES AND HAZARDOUS
PROPERTIES .............................................................................................19
1.8.1 Introduction.................................................................................19
1.8.2 Hazardous properties ................................................................19
1.9 ESTIMATING QUANTITIES OF WASTE ....................................................21
1.10CLASSIFICATION OF SCHEDULED WASTES.........................................22
1.10.1 Introduction.................................................................................22
1.10.2International Approaches ...........................................................22
1.10.3The Malaysian System ................................................................23
1.11SUMMARY OF PROCEDURE FOR IDENTIFICATION AND
CLASSIFICATION.......................................................................................26

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 1

MODULE 1

SCHEDULED WASTES MANAGEMENT AND IDENTIFICATION

AND CLASSIFICATION OF SCHEDULED WASTES

1.0 INTRODUCTION TO MODULE 1

Scheduled wastes are potentially harmful. Normal handling

(storage, packaging, and transport) and the subsequent disposal
methods, that normally be used for non-hazardous industrial
wastes (typically land filling), are usually not appropriate, because
scheduled wastes present potential risks:

 to human health
 to the environment
 of accidents

If they are stored on-site without necessary precautions or dumped

illegally they may also present long term risks to the environment.

Thus a good scheduled waste management approach is essential

to be embarked not only to conform to the Regulation imposed but
also to safe guard the human health and environment.
The module will focus on:

 Concept of Scheduled Waste Management

 Concept Cradle to Grave
 Waste Management Hierarchy
 The legislative background
 Identifying scheduled wastes
 Classifying scheduled wastes
 Hazardous properties
 Potential risk with and hazardous substances in scheduled
wastes
 Determining properties of scheduled wastes
 Good handling scheduled wastes

It presents methods and examples derived from international

principles and methodologies, such as the Basel Convention and
the European system for classifying and identifying of hazardous
waste. Although the Malaysian definition of scheduled wastes is
intended to be comprehensive, the classification of certain waste
types will always be open to interpretation. Therefore information

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 2

from other systems can be useful as further reference, such as to

refine the classification of certain scheduled wastes types further
where necessary, but also to enhance the understanding of the
underlying principles in classification of scheduled wastes.

The fundamental knowledge on identification, classification and

properties of scheduled wastes will form the basis for the further
modules in the training package.

1.1 INTRODUCTION

1.1.1 Purpose

In order to control the environmental impact of scheduled wastes, it

is first necessary to know whether a material is a scheduled waste
and, if so, how to classify it and what its properties might be.
Understanding of basic principle of Scheduled Waste Management
such as concept of Cradle to Grave will determine scheduled
wastes generated will be managed correctly. This module provides
training in these matters, which is fundamental for all the
Scheduled Wastes handlers / managers.

1.2 SCHEDULED WASTES MANAGEMENT

The rapid development of manufacturing, agricultural and

commercial industrial in Malaysia have contributed tremendous
economic contribution to the country. As such, economy is seen as
generating pressures for outward growth as the investment has
contributed greatly to the shining performance of the manufacturing
sectors while the environment presents unavoidable constraints.

This resulted a number of environmental related problems surfaced

parallel to development efforts. At the same time, unavoidably
these sectors and their production activities have led to generation
and accumulation of waste materials, which could be categorized
under toxic and hazardous wastes. These kinds of waste materials
are better known as scheduled wastes under the Environment
Quality Act, 1974.

1.2.1 Scheduled Wastes Management in Malaysia

Generally, management of waste after it is generated requires

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 3

investment in pollution control equipment and expenditures of

material and energy that would not be required if the waste is not
generated. Because of the growing appreciation of the benefits of
waste avoidance, the overall approach to waste management in
the Malaysia has begun to shift from pollution control driven
activities to pollution prevention activities as suggested in table
below.

Evolution of Schedule Waste Management Approaches in

Malaysia
Year Approaches
Prior – 1970 No Control
1970 – Some/little control
1974
1974 – 1980 Greater control, Environmental Quality Act came into
force
1980 – 1985 More comprehensive control, Department of
Environment, Malaysia established
1985 – 1990 Beginnings of hazardous waste
management
1991 – 1996 Waste reduction management, Malaysia
Agenda for Waste Reduction (MAWAR)
launched
1997 – 2000 Widespread acceptance of Pollution
Prevention
>2000 Sustainable Development, Cleaner
Technology Design for Environment

As Malaysian gains momentum in her efforts to achieve industrial

status by the year 2020, efforts to minimize waste generation,
recycle waste and adopt pollution prevention measures must be
intensified. The scheduled waste generated from those industries
described requires environmentally sound management especially
in the areas of safe handling and recovery to ensure the safety and
security of the environment. In 2004, more than 400,000 tones of
scheduled wastes were produced by waste generators in Malaysia.

According to the Malaysia Environmental Quality Report 2004,

current estimates indicate that metal, chemical and electric and
electronic industries made up the main categories of scheduled
waste generator in the country. The breakdown according to waste
categories and industry types are given in Figure 1 and Figure 2
respectively.

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 4

WASTE CATEGORY

Dross/ Slag/ Clinker 35.86

Mineral Sludge 21.33

Oil & Hydrocarbon 12.78

Heavy Metal Sludge 10.4

Others 5.37

Acid/ Alkali 3.06

Clinical 2.38

Paint/ Ink/ Dye/ Solvent 2.21

Rubber & Latex 1.57

Ink/ Paint/ Dye Solvent 1.26

1.11
Containers

On Halogen Solvent 0.52 Total Quality of Waste Generated :

400,000 Tonnes / Year
0.46
Phenol/ Adhesive/ Resin

Figure 1:Catalyst
Quantity0.43 of Scheduled Wastes Generated by Waste Category

0.39
Paper & Plastic

0 5 10 15 20 25 30 35 40

PERCENTAGE (%)

Figure 1: Quantity of Scheduled Wastes Generated by Waste Category

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 5

INDUSTRY

Metal 35.12

16.48
Chemical

14.15
Electrical & Electronic

Others 6.43

5.49
Machinery

3.73
Rubber & Plastic

Power Generator 3.71

Prescribed Premises 3.53

Petroleum 2.99

Textile 2.23

Clinical / Hospital 1.87

Printing & Packaging 1.56 Total Quality of Waste Generated :

400,000 Tonnes / Year
Industrial Gas 1.51

Paint Manufacturing 1.19

0 5 10 15 20 25 30 35 40

PERCENTAGE (%)

Figure 2: Quantity of Scheduled Wastes Generated by Industries

Such schedule waste management is a process and tool which

effectively manages could protect human health and the

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 6

environment. This method of waste management has certain

disadvantages. Specifically this type of pollution control does not
always solve the problem of pollution; rather, it often transfers
pollution from one medium to another, resulting in no
environmental benefit. Thus the principle of Cradle To Grave is
the key concept of scheduled wastes management in the country

1.3 PRINCIPLE OF CRADLE TO GRAVE

Toxic and hazardous waste is one of the environmental key issues

of Malaysia. Monitoring of these wastes means that the
whereabouts of such wastes are known at all times; “from cradle to
grave” as shown in Figure 3.

Control of hazardous wastes can fully be achieved when adequate

facilities are available. Control means that competent authorities
can act rapidly to assure that the possibility for inappropriate
handling of wastes or dumping are minimized. Control means also
that the authorities have the power, both legally and financially, to
act quickly in order to reduce danger posed to men and the
environment. For adequate monitoring and control, countries need
legislation on hazardous waste for the regulatory body and to be
complied by the schedule waste generator.

The components of cradle to grave of the schedule waste

management are:

i. Waste generator;
ii. Waste contractor/transporter; and
iii.Waste treatment and disposal facilities.

i. Waste generator

 Reduce or minimize to the extent possible the generation of

waste at source;
 Re-use or recycle waste whenever possible;
 Render wastes innocuous before disposal;
 Dispose wastes only at approved sites;
 Place wastes in appropriate container marked with proper label;
 Develop an emergency procedures for accidental spillage of
schedule waste;
 Complete the ‘Consignment Note’ and submit to the Department
of Environment; and

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 7

 Establish/submit (if applicable) to the Department of Environment

regular basis an inventory of schedule waste generated.

ii. Waste contractor/transporter

 Obtain the necessary approval transportation of schedule wastes

from appropriate authorities;
 Complete the ‘Consignment Note’ and submit to the Department
of Environment;
 Ensure that the vehicles used for transportation are specially
designed safe delivery of schedule wastes;
 Follow the recommended routes; and
 Ensure that schedule wastes reach the treatment disposal sites
safely.

iii. Waste treatment and disposal facilities.

 Obtain the construction and operation licenses from the

Department of Environment;
 Comply with every provisions of the legislations and regulations;
 Establish an emergency producer for any accidental spillage;
 Complete the ‘Consignment Note’ and submit to the Department
of Environment; and
 Conduct research to improve the efficiency of schedule waste
treatment and disposal.

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 8

Figure 3: Principle ‘Cradle to cradle’

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 9

1.4 SCHEDULED WASTES MANAGEMENT HIERARCHY

In general, schedule waste management hierarchy should adopt the

principle of pollution prevention:

 Source reduction
 Re-use/recycling
 Treatment
 Disposal

1. Waste 2. Reuse/ 3. Treatment

Reduction Recycling Does 4. Safe
Can quantify of Can waste be hazardous Landfill /
waste produced reused or nature of waste Disposal
be minimized? recycled? need to be
reduced?

Figure 4: Schedule Waste Management Hierarchy

There are significant opportunities for industry to reduce or prevent

pollution at source through cost-effective changes in production,
operation and raw materials use, which will result to have reduced of
wastes. The opportunities for sources reduction are often not realized
because existing regulations, and the industrial resources they require
for compliance, focus upon treatment and disposal rather then source
reduction. Source reduction is fundamentally different and more
desirable than waste management and pollution control.

Whilst, pollution that cannot be prevented should be recycled in an -]

environmentally safe manner. This secondary approaches, recycling,
reuse and recovery attempt to recover a usable material from a waste
stream. The methods involve can take place within the process, or at the
end of the process and can be implemented either on or off-site.

In the absence of feasible prevention or recycling opportunities, pollution

should be treated; disposal or other release into the environment should
be used as a last resort.

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 10

Figure 5, depicts the hierarchy of preferred approaches to integrated

waste management, and ultimately pollution prevention.

FOCUS STRATEGY

Eliminate Pollution

Recycle Prevention

Reuse Waste Management

Reduce Waste Management

Control &
Treat &
Disposal
Dispose

Figure 5: Pollution Prevention Hierarchy

Pollution prevention hierarchy can be depicted as an inverted

triangle, where the area of the band denoting the management option
is indicate of the amount of pollution involved. The objective of
scheduled wastes management is to make the pointed base as small
as possible.

1.5 IDENTIFICATION AND CLASSIFICATION OF SCHEDULED WASTES

1.5.1 What is meant by Identification and Classification?

Scheduled waste is a category of industrial waste needing special care

in handling, treatment and disposal due to the potential adverse
impacts resulting from the hazardous properties of the waste. There are
two stages: the waste must first be identified as scheduled waste, it is
then necessary to classify it in order to determine how it should be
stored, handled, treated and disposed of.

Identification of scheduled waste is the procedure of determining

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 11

whether a specific waste from an industrial source is scheduled waste

or not. This may be done from information on its chemical composition,
its properties, or the source of the waste.

Classification of scheduled waste is the procedure used to specify the

type of waste. Scheduled wastes are classified into different types (e.g.
spent oil-water emulsions used as coolants).

The understanding of the underlying principles of identification and

classification requires a fundamental chemical knowledge together with
knowledge of the hazardous properties of chemical substances, such
as:

 Explosivity
 Flammability
 Corrosivity
 Reactivity
 Human toxicological properties
 Ecotoxicological properties

Chemical knowledge (basic chemistry and chemical processes) is

necessary to be able to identify waste types, to predict the generation
of –scheduled wastes, to identify scheduled wastes and to identify the
appropriate treatment techniques for scheduled wastes. Knowledge of
hazardous properties is necessary to understand why specific waste
types need handling/treatment as hazardous waste and to understand
the specific requirements in relation to handling of scheduled wastes
(sorting, segregation, storage and transport). It is also useful in the
discussion of specific classifications of scheduled wastes with waste
generators as they often will argue that their wastes do not need
special treatment as they are not hazardous.

1.6 LEGISLATIVE BACKGROUND FOR CLASSIFICATION OF

SCHEDULED WASTES

1.6.1 Introduction

The primary legislation influencing the classification of scheduled waste

is the Environmental Quality Act 1974 (EQA 1974) with its
amendments. The EQA is supported by secondary legislation
comprising a number of regulations and orders of which the most

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 12

important are the Environmental Quality (Scheduled Wastes)

Regulations, 2005 - known as the Scheduled Wastes Regulations. It is
these Regulations which provide the basis for classification of
scheduled wastes and they include (in the First Schedule) the specific
list of scheduled wastes.

1.6.2 Definition of Waste

Waste is defined in the EQA 1974 as:

“Any matter prescribed to be scheduled waste or any matter whether in

a solid, semi-solid or liquid form, or in the form of a gas or vapour,
which is emitted, discharged or deposited in the environment in such
volume, composition or manner as to cause pollution.”

This definition is appreciably different from that which is widely used

internationally. In the EU and many other countries, waste is defined
as any material which the holder discards or intends to discard. The
Basel Convention definition is similar but uses the term “dispose of”
instead of “discard”.

In Malaysia, therefore, a material only becomes waste at the point at

which it is emitted, discharged or deposited – and then only if it causes
pollution. It could thus be argued that material which would, in most
countries, be considered to be waste may not be waste if it is managed
in a manner so as to cause no pollution.

This being said, in most cases materials which would be waste in other
countries will also be considered waste in Malaysia.

1.6.3 Definition of Scheduled Wastes

Under the regulations, scheduled waste is defined as “any waste

falling within the categories of waste listed in the First Schedule”.
Consequently, it is only possible to confirm that a waste is scheduled
when it has been classified.

Every waste type mentioned in the First Schedule must be considered

as scheduled waste regardless of its hazardous properties. The list of
waste types is divided in identifies by their composition specified
source.

These regulations currently in force and it must be recognised that the

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 13

inspection and regulation process must work within them.

 Group 1 : SW1 – Scheduled wastes from metal and metal –

bearing wastes
 Group 2 : SW2 - Scheduled wastes from wastes containing
principally inorganic constituents which may contain metals
and inorganic materials.
 Group 3 : SW3 – Scheduled wastes from wastes containing
principally organic constituents which may contain metals and
inorganic materials.
 Group 4 : SW4 – Scheduled wastes from wastes which may
contain either inorganic or organic constituents.
 Group 5 : SW5 – Scheduled wastes from other wastes.

Examples of wastes listed in Group 1 - 5 of the First Schedule are

given below. The complete list is available in the Scheduled Waste
Regulations.

SW I: Metal and Metal – bearing wastes

1. Mineral oil and oil contaminated waste

SW101 Waste containing arsenic or its compound

SW102 Lead acid, batteries, in whole or crushed form
SW110 Waste from electrical and electronic assemblies
containing components such as accumulators,
mercury-switches, glass from cathode-ray tubes or
contaminated with cadmium, mercury, lead, nickel,
chromium, copper, lithium, silver, manganese or
polychrominated biphenyl.
SW5 : Other waste
SW501 : Any residues from treatment or recovery of scheduled wastes

Lists of waste from specific sources are helpful for enterprises

falling within these categories as it will generally be easy for them
to classify their waste. Waste production, however, is not always
predictable and therefore enterprises categorised as specific
sources may produce waste not identified explicitly in the list.

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 14

1.7 IDENTIFICATION OF SCHEDULED WASTES

1.7.1 Introduction

Identification of scheduled waste is the process of determining whether

a specific waste has to be considered as scheduled waste. Scheduled
waste is defined, as explained in section 1.2, by reference to the list of
waste types in the First Schedule to the Environmental Quality
(Scheduled Wastes) Regulations 2005.

Hence having determined that a material is waste, it is necessary to

assess whether it falls into one of the categories of scheduled waste.
This can only be confirmed by classifying the waste. There are,
however, a number of preliminary steps that may be taken to obtain an
indication of the presence of scheduled wastes.

The first step is to obtain a description of the waste from the generator.
This may immediately determine that it is scheduled waste. The waste
should, however, be examined to assess whether the classification
provided appears to be correct. A review of its basic properties (see
below) should normally be sufficient to confirm this.

The next step is to determine whether the waste is clearly identifiable

as being a non-scheduled waste, which can then save a considerable
amount of further time.

Whilst, as has been explained, the legal definition of scheduled waste

is by reference to a list of wastes, the essence of the issue – and the
spirit, if not the fact, of the legislation – is: is the waste likely to
present a serious threat to human health or the environment? If
the answer to this question is “yes”, then the waste is likely to be
scheduled waste.

Now, how does one decide whether a waste may cause a serious
threat to human health or the environment? The answer is that most
wastes which have these properties are by and large, chemical and oil
residues of one kind or another. These can usually by determined by
identifying:

 The source of the waste

 The basic physical and chemical character of the waste

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 15

It is vital to appreciate, however, that although the basic properties

will give an indication of whether a waste is scheduled waste, this
cannot be confirmed until it is classified.

1.7.2 Identifiable non-scheduled waste

If a waste is clearly identifiable as a waste type which is not a

scheduled waste, then it is clearly not a scheduled waste. This may
seem obvious, but it is actually one of the simplest ways of
determining that a material is not a scheduled waste.

Some of the commonest identifiable wastes which are not scheduled

waste are:

 Municipal solid waste

 Construction and demolition waste
 Commercial waste - from offices, hotels, shops etc.
 General industrial waste consisting of paper, cardboard, plastic
timber, metal etc.
 Sewage sludge
 Potable water treatment sludge

Some of these wastes could, on occasions, be scheduled wastes – for

example construction and demolition wastes containing asbestos – so
it is important to examine them, but the presence of scheduled wastes
will normally be clearly evident.

1.7.3 Source of the waste

If a waste is produced by an industry which uses hazardous materials

in its process, then there is a chance that it may be scheduled waste
although, of course, this is not certain until it has been classified.

The first step, therefore, is to consider whether the producing industry

uses hazardous materials. This can be determined by reference to the
Materials Data Safety Sheets (MSDSs) for the input materials, which
must be available.

A mass balance can also give a better idea of whether scheduled

wastes are being produced. It is important for the industries to have
their self-checking of the mass balance of the waste generated.

1.7.4 Basic physical and chemical character of the waste

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 16

If a waste is known to be scheduled waste, generators are required

under Regulation 13 of the Environmental Quality (Scheduled Waste)
Regulations 2005 to provide the following information for wastes which
they consider to be scheduled waste.

 Category of waste
 according to the First Schedule
 Origin
 from which process, activity, occurrence, etc. the waste is generated
 Physical properties of waste
 Flash point
 boiling point
 consistency with room temperature (gas, liquid, sludge, solid)
 vapours lighter/heavier than air
 solubility in water
 waste lighter/heavier than water
 Risks
 by inhalation
 by oral intake
 by dermal contact

If this information is not provided – for example, if the generator does

not consider it to be scheduled waste – then it will be necessary for
DOE staff to ascertain as much as possible about the waste with the
waste generator had to declare their waste properties. This initial
description will then have to be followed by a more detailed chemical
analysis of the waste.

There are three aspects to basic physical and chemical assessment.

The first is based on visual assessment of its physical state. This can
be divided into three main categories (solids, liquids, and sludge) and
each of the main categories can be divided further:

 Solid
- Powder
- Mineral fibres
- small pieces
- medium size
- large size
- unknown

 Liquid
- aqueous solution
- emulsion

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 17

- oil
- other hydrocarbon
- unknown

 Sludge
- wet
- dry
- non-aqueous
- unknown

The second involves the assessment of basic chemical description and

characteristics and may be done by means of a visual assessment and
simple field tests prior to chemical analysis:

 Basic chemical description of the waste

- organic waste (chemical or photochemical origin)
- organic waste (biological origin)
- metallic waste
- mix of organic materials
- mix of inorganic and organic materials
- mix of organic materials
- unknown composition

 acidity/alkalinity:
- acidic waste
- basic waste
- neutral waste
- unknown

 Flammability:
- highly inflammable
- combustible
- combustible in contact with other material or if dried
- not combustible
- unknown

 Reactivity:
- with water
- with air

Assessment of the acidity/alkalinity can be done by simple means (e.g.

litmus paper or pH meter) whereas identification of flammability
requires physical tests, which should be approached with caution.
Nevertheless a very small sample can be placed on a metal dish (or

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 18

lid) and an attempt made to ignite it. Similarly reactivity with water can
be tested with a very small sample. Reactivity with air, which is not
commonly experienced, will be evident without any special tests.

The third step is to identify any other evident characteristics, in

particular:

 Its odour
 Direct evidence of hazardous properties, such as corrosivity
(which may be tested with a small piece of iron or other foil) or
volatility (which will be evident by evaporation and the
pr4esence of fumes.

Having made this assessment, it is usually possible to get an

indication as to whether the waste is likely to possess hazardous
properties and therefore be scheduled waste. Some examples of such
deductions are:

 Liquids and sludges are more likely to contaminate water than

insoluble solids
 Finely divided material may be more hazardous than larger
pieces – e.g. with certain metals (e.g. Mg, Al)
 Highly volatile materials virtually always possess hazardous
properties

1.7.5 WHAT DO SCHEDULED WASTES LOOK LIKE?

Scheduled wastes are usually stored in metal or plastic drums –

generally old, dirty ones – but may also be found in large storage
tanks (in the case of liquids), open transport containers (“skips”), fibre
kegs, cardboard boxes or, for solids, simply in heaps.

They may take the form of a liquid, sludge, a powder or solid lumps.
Generally they appear dirty and do not look like a useful product or
material, although off-specification products, such as solvents, paints
or pharmaceuticals, may also be wastes, in which case they may be
difficult to distinguish from normal products.

Examples

Some pictures of scheduled wastes will be shown by the trainer

during the presentation.

Certification Course Environment Institute of Malaysia,

Department of Environment
EiMAS Training Material
Course Title: Certified Environmental Professional in Schedule Waste Management
Module 1: Overview PAGE 19

1.8 HAZARDOUS SUBSTANCES AND HAZARDOUS PROPERTIES

1.8.1 Introduction

Scheduled wastes are, or should be, characterised by hazard

properties that are caused by the content of hazardous substances.
The different types of hazard properties are described in this section.
Knowledge of this topic is required:

 To understand the risks presented to human health and the

environment – including to his/her own health.
 To recognise that a waste might be appropriate to be
classified as scheduled waste
 to understand the requirements for handling of scheduled
wastes
 to understand why specific waste types need special handling
and treatment

Also, in the process of identification and classification of scheduled

waste, the waste generator is advised the needs to discuss the validity
of the actual classification with the DOE.

1.8.2 Hazardous properties

Chemical products for use in industry must be classified according to

the Occupational Safety and Health (Classification, Packaging and
Labelling of Hazardous Chemicals) Regulations 1997 made under the
Occupational Safety and Health Act 1994. For each product, a
Materials Data Safety Sheet (MSDS) must be prepared. Since
hazardous wastes are seldom, if ever, produced from materials which
are not hazardous within themselves, knowledge of the classification
of raw materials used in a specific process gives an indication of the
possibility of generation of hazardous waste.

The list of hazardous properties used to characterise hazardous waste

can be more or less detailed depending on whether the goal is to
consider all possible effects or only those that can be tested with

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relatively simple equipment.

The hazardous properties of chemical wastes may be greater than

those of the individual constituents due to interaction between them.
The prediction of combined effects, however, is a difficult task and,
consequently, attention is normally limited to considering the
properties of the constituents only.

A good example of a list of hazardous properties is that used in the

European waste classification system. It is, with a few exceptions;
identical with the list of properties included in the Basel Convention
(see Appendix B) to which Malaysia is a party. It is therefore relevant
for Malaysia and is shown in Table 1.

Testing waste for hazardous properties is expensive and takes a

significant amount of time; consequently, the classification of waste is
usually based on the hazard classification of the specific substances
present in the waste. This, once again, emphasises the need for a
chemical analysis.

Table 1 EU list of hazardous properties

Explosive: substance and preparations which may explode under the effect of flame or
which are more sensitive to shocks or friction than dinitrobenzene

Oxidizing: substances and preparations which exhibit highly exothermic reactions when
in contact with other substances, particularly flammable substances

Highly flammable:
– liquid substances and preparations having a flash point below 21°C (including
extremely flammable liquids), or
– substances and preparations which may become hot and finally catch fire in contact
with air at ambient temperature without any application of energy
– solid substances and preparations which may readily catch fire after brief contact
with a source of ignition, or
– gaseous substances and preparations which are flammable in air at normal
pressure, or
– substances and preparations which, in contact with water or damp air, evolve highly
flammable gases in dangerous quantities

Flammable: liquid substances and preparations having a flash point equal to or greater
than 21°C and less than or equal to 55°C.

Irritant: non-corrosive substances and preparations which, through immediate,

prolonged or repeated contact with the skin or mucous membrane, can cause

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inflammation.

Harmful: substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may involve limited health risks.

Toxic: substances and preparations (including very toxic substances and preparations)
which, if they are inhaled or ingested or if they penetrate the skin, may involve serious,
acute or chronic health risks and even death.

Carcinogenic: substances and preparations which, if they are inhaled or ingested or if

they penetrate the skin, may induce cancer or increase its incidence.

Corrosive: substances and preparations which may destroy living tissue on contact.

Infectious: substances containing viable micro-organisms or their toxins which are

known or reliably believed to cause disease in man or other living organisms.

Teratogenic: substances and preparations which, if they are inhaled or ingested or if

they penetrate the skin, may induce non-hereditary congenital malformations or
increase their incidence.

Mutagenic: substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may induce hereditary genetic defects or increase their incidence.

Substances and preparations which release toxic gases in contact with water, air or an
acid.

Substances and preparations capable by any means, after disposal, of yielding another
substance, e.g. a leachate, which possesses any of the characteristics listed above.

Ecotoxic: Substances and preparations which present or may present immediate or

delayed risks for one or more sectors of the environment.

1.9 ESTIMATING QUANTITIES OF WASTE

Sometimes it is necessary to estimate the quantity of waste – in terms of

weight (mass), from inspection. It is helpful to have some approximate
conversion factors for the commonly used waste containers.

Regular drums contain 200 litres (45 imperial gallons, 55 US gallons).

For oils and organic solvents, the weight may be around 160 kg per
drum. For aqueous wastes, the weight will be around 200 kg. For
inorganic sludges, the weight could be as much as 300 kg, although 250

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kg is more typical.

“Carboys” are smaller plastic containers, typically with a capacity of 25

litres. The appendix conversion factors are same as for regular drums.

1.10 CLASSIFICATION OF SCHEDULED WASTES

1.10.1 Introduction

The identification of a waste as a scheduled waste must be followed by

its classification, i.e. the assigning of a waste code. This section
describes how this is done.

It is helpful to see the Malaysian system of classification of scheduled

waste in an international context. This is especially true since Malaysia
is a party to the Basel Convention sponsored by the United Nations
Environment Programme (UNEP) and, consequently, must abide by the
Basel Convention procedures when importing or exporting hazardous
wastes.

1.10.2 International Approaches

The parties to the Basel Convention have, to some extent, taken a

common approach to the issue of definition and classification of
hazardous waste. The Basel Convention system uses a system of 45
waste categories.

Within many countries throughout the world – North America, the EU,
Central and Eastern Europe and many other countries – however,
classification systems have been developed which go further than that
required by the Basel Convention. A classification system was
developed in the EU and implemented in 1994 which involves about 250
waste categories classified as hazardous.

The key aspects of the Basel Convention system, as well as those in

North America and the EU is that, for a waste to be hazardous (i.e., in
the case of Malaysia, scheduled waste) it must contain certain defined

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hazardous materials (or come from certain specific sources) AND/OR

must possess certain hazardous properties. The reason for this is that a
waste might contain a potentially hazardous material in such low
concentrations that it presents no risk to human health or the
environment. It would then not be economically sound to treat it as a
hazardous waste, since the cost of so doing would be substantially
greater. The system in use in both the EU and USEPA involves a
similar approach.

A more detailed description of the principles used for definition of

hazardous waste in the Basel Convention and the European hazardous
waste directive is presented in Appendix B and C respectively.

1.10.3 The Malaysian System

In Malaysia, classification is undertaken by reference to the First

Schedule in the Scheduled Wastes Regulations, 2005 as explained
above. The categories are intended to be self explanatory. There is no
substitute for becoming fully familiar with the detailed waste codes as
shown in the regulations.

There is currently no specific provision in the legislation for the defining

scheduled wastes by their hazardous properties. This, however, is
clearly within the spirit of the legislation - by virtue of waste being
defined as causing pollution. Administratively, Malaysia has adopted
USEPA in specifying four hazard properties for the characterization of
scheduled wastes (hazardous waste):-

(1) Ignitability
(2) Corrosivity
(3) Reactivity
(4) Toxicity

If it is not clear what the classification of a waste should be, then a

chemical analysis be carried out at the accredited laboratory or by the
Chemistry Department must be undertaken, at the expense of the
generator. Care should be taken, however, in the sampling process, to
ensure that the sample is truly representative. The sampling should
therefore be supervised, or even overseeing by a DOE officer.

It should be recognised, when calling for an analysis, that it is important

to identify the presence of the materials which are suspected of causing
hazardous properties.

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Properties of Wastes Which Render Them Hazardous

Waste is regarded as hazardous if it demonstrates one or more of the

following properties. If the waste contains a mixture with one or more
chemical substances which demonstrate these properties, evaluation
shall take into account the total content of these substances, as
specified in below.

Fire hazard 1. Explosive: solid, liquid, paste-like, or gelatinous

substances or products which, without the effect of flame,
can react to produce violent generation of heat with rapid
generation of gas, and which under specific test
conditions detonate and rapidly deflagrate, or when
heated impart confinement, explode.
2. Oxidising : Substances or products which exhibit
Highly exothermic reactions when in contact with other
substances, particularly flammable substances.

3. Flammable : Substances or products (including those

which are extremely flammable and highly flammable)
which :
 Become hot and finally catch fire in contact with air at
ambient temperature without any application of
energy; or
 In solid form may readily catch fire after brief contact
with a source of ignition and which continue to burn or
be consumed after the removal of the source of
ignition; or
 In liquid form have a flash point of lower than 0’C and
a boiling point lower than or equals to 35’C (extremely
flammable) ; a flash point below 21’C (highly
flammable); a flash point equals to or greater than
21’C and less than or equals to 55’C (flammable); or
 In contact with water or damp air evolve highly
flammable gases in dangerous quantities, or
Health hazard 4. Very toxic : Substances or products which :
 If they are inhaled or ingested , or if they penetrate the
skin may involve extremely serious, acute or chronic
health risks or even death ; or

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 The LD50 absorbed orally in rat is less than 25 mg/kg

or the LD-50 percutaneous absorbed by inhalation in
rat is less than 0.5 mg/liter (administered for a
minimum period of four hours)
5. Toxic : Substances or products which ;
 If they are inhaled or ingested, or if they penetrate the
skin may involve serious, acute or chronic health risks
or even death; or
 The LD50 absorbed orally in rat is between 25 to 200
mg/kg or the LD-50 percutaneous absorption in rat or
rabbit is between 50 to 400 mg/kg or the LC-50
absorbed by inhalation in rat is between 0.5 to 2
mg/liter (administered for a minimum period of four
hours)
6. Harmful : Substances or products which:
if they are inhaled or ingested, or if they penetrate the
skin may involve limited health risks; or
The LD50 absorbed orally in rat or rabbit is between 200
to 500 mg/kg or the LD-50 percutaneous absorption in rat
or rabbit is between 400 to 2000 mg/kg or the LC-50
absorbed by inhalation in rat is between 2 to 20 mg/liter
(administered for a minimum period of four hours)
7. Corrosive: Substances or products which
may destroy living tissue on contact.
8. Irritant: Substances or products which,
without being corrosive, may cause
inflammation through immediate, prolonged or
repeated contact with the skin or mucous
membrane.
9. Carcinogenic: Substances or products which
if they are inhaled or ingested, or if they
penetrate the skin, may induce cancer or
increases its incidence.
Harmful to the 10. Ecotoxic: Substances or products which
environment present, or may present immediate or delayed
risks for one or more segment of the
environment.
Infectious 11. Infectious: Substances containing micro-
organisms or their toxins which are known or
reliably believed to cause disease in man or
other living organisms.

The precise detail on other components is of lesser importance. Thus,

when analysing a cyanide waste, the cyanide concentration is of great
relevance, whilst the precise concentration of sodium or potassium

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chlorides, nitrates etc. is of little interest.

From the chemical composition it should then be possible to make a

classification.

1.11 SUMMARY OF PROCEDURE FOR IDENTIFICATION AND

CLASSIFICATION

It will have been seen that the process of identification and

classification is a seamless one, since identification cannot be
confirmed until the waste has be classified. The basic procedure for
identification and classification of scheduled waste is summarised in
flow chart 1:

Flow Chart 1

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Obtain
description of
waste from
producer

Is the waste
Is description in
Yes No clearly non- Yes
First Schedule?
scheduled?

No

Consider source of
waste and whether
hazardous materials
are used in process

Determine basic
properties of
waste

Does the waste Does the waste

appear to conform No Yes appear to have
with the hazardous No
description? properties?

Yes

Demand an
analysis

Identify
Use classification components and Probably not
provided classify scheduled waste
accordingly

Certification Course Environment Institute of Malaysia,

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Module 2 : Identification, Classification and Properties of Scheduled waste REFERENCES

It will be seen that one of the key steps in this flow chart is the
identification of whether the waste is likely to have hazardous
properties. The existence of hazardous properties is important not only
in determining whether the waste should be classified as scheduled
waste but also for the protection and safety of those who come in
contact with it – including the industries as well as DOE officers
themselves.

Certification Course Environment Institute of Malaysia,

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Course Title : Scheduled wastes Management
Module 2 : Identification, Classification and Properties of Scheduled waste REFERENCES

REFERENCES

Legislation and regulation

Occupational Safety and Health (Classification, Packaging and Labelling of

Hazardous Chemicals) Regulations 1997

UNEP. Basel Convention on the control of Transboundary Movement of

Hazardous Wastes and their Disposal.

UNEP (1998). Report of the fourth meeting of the conference of the Parties to
the Basel Convention. Kuching, 23-27 February 1998. UNEP/CHW.4/35, 18
March 1998.

Suggested additional reading

Nemerow NL, Agardy FJ (1998). Strategies of Industrial and Hazardous Waste

Management. New York: Van Nostrand Reinh

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