Iwms & master plan

Policy recommendation report to EEAA on
An Integrated Waste Management System
for mercury containing Hazardous Waste
Dec. 2009
KOICA and ENVICO

Chapter1. Introduction
1.1 Background
Management of solid waste in Egypt is very poor. In the greater Cairo region, waste collection
is made by private companies in contracts with Governorates. Governorates collect waste fees from
the residents, invoiced with electricity bill and repay the companies. The revenue from waste fees is
not enough for the payment to the companies. Many residents do not pay the fees. Governorates run
deficit in the waste account and the private companies do not collect waste. Waste are dumped in all
over the regions and left uncollected.
The poor management of municipal solid waste casts a severe problem with the hazardous
waste such as FLW. Hazardous wastes are not separated and collected together with other non
hazardous wastes or simply dumped on the roads and streets uncollected. Most of the FLW are
broken and the mercury contained in the lamps is emitted untreated into the air. The worst thing is that
people do not understand its risk to health. Not only public but also officials in charge of waste at the
central government as well as local authorities do not recognize the significance of the danger.
Another problem comes from the FL manufacturers. The factories produce large volume of
defected FLs due to poor quality control. Average rate of defected goods out of total products reaches
to %. All the defected goods are reused at site without a proper treatment of the mercury. It is easily
imagined the site is heavily contaminated by mercury and workers are exposed to a very dangerous
working condition.
The EEAA has come to recognize this situation and to decide to solve this problem by
constructing a FL recycling facility. Egyptian government applied KOICA for an aid in this field and
KOICA decided to provide an aid for construction of a FL recycling facility with some professional
consultancy services regarding policy and administration matters required to guarantee the normal
operation of the factory under the name of the Project for the Management of Mercury Waste.
KOICA had dispatched an expert of waste policies to study the current status of mercury
waste management in Egypt, and to provide the government with consultancy on establishing an
efficient waste collection system of FLWs and on formulating policies & programs for supporting the
Mercury Waste Project. The policies and programs include;
a. general scheme of collection and treatment of FL wastes
b. organizations- and responsibility sharing among the stakeholders
c. financing and implementation strategies
d. draft for new legislation
e. revision of existing laws & acts related

This report is about the above consultancy services. It summarizes the current status of infra
structures and actual management of mercury containing waste to identify problems. It suggests
some solutions by recommending to establish an IWMS for FLWs with a list of infra structures,
facilities & equipments, manpower and legal as well as social systems to support the management
system. It also suggests a phase-wise implementation strategy considering the capacity of Egyptian
government. The primary goal of this consultancy report is to recommend EEAA to make policies for
the establishment of a stable supply system of the FL waste and a sustainable financing scheme for
the normal operation of the recycling facility to be constructed. It will introduce various alternative
policy tools for the establishment of the IWMS and suggest a most feasible scheme with a practical
implementation plan in consideration of the current socio-economic conditions and environment of the
country and government capacity.
1.2 Method and scope of research
The primary goal of this report is to find out a system for safe and economical management
system for FL wastes. For this goal, the report provides a review of the surveys conducted by joint
working group of Korean expert and EEAA personnel on current status of mercury waste
management. The surveys are preliminary survey on the general status of FL manufacturers and field
survey on sources, waste volumes, discharging practice, collection and treatment status of FL wastes.
The scope of hazardous waste is limited to mercury containing waste. They include industrial
waste from electrolysis process (NaOH, KOH), mercury using factories (thermometers, barometers,
rectifier, catalysts etc.). The mercury substances generated in the form of air pollutants emitted from
the factories with processes of metallurgy, iron-metal alloy, cement, glass, waste incineration are
excluded. The primary focus will be given on the FL wastes and sometimes on waste thermometers of
which the waste volume is large enough to cast environmental problems. Other mercury containing
wastes discharged in a small quantity are considered only when laws and acts concerning hazardous
waste are related. The legal systems and policy programs cover all the jurisdictions of the nation, but
for collection and financing plans for the project, the geographical regions may be restricted to greater
Cairo regions or some regions near Alexandria Governorate.
1.3 Activities undertaken by the expert
The waste policy expert has been dispatched three times to the field to have a site study, to
interview various stakeholders & government officials and to collect documents and materials. The
expert had a regular meeting with the government officials in charge of this project and Korean PMs
and KOICA personnel. The expert has had several site tours of the source areas and planned facility
site.

The expert has guided the survey team by providing survey team with questionnaires and
guidelines instructing regions and targets to be surveyed. The whole process of survey has been
reviewed by the expert and the result & statistics has been analyzed to identify problems on issue,
measuring their significances to assign priorities. The urgent problems to be tackled by this project
and other problems to be considered in later time are classified and decided.
A review work has been conducted on laws and acts concerning hazardous waste
management together with government policies and programs including government budgets. The
expert made a master plan for the FLW problems. The plan classified the scope of waste generating
sources into four groups each of which will be tackled by a different phase strategy under different
implementation plan. The plan proposes a policy suggestion for establishing an efficient and stable
supply system of the FL wastes and a stable financing scheme. The plan suggests
a. general idea of IWMS to be implemented over a long time period
b. an efficient collection scheme for this project (the quantity of FL wastes enough for the
normal operation of the facility to be constructed by this project)
c. list of facilities and other infra structures required for the implementation of each phase
of the IWMS plan
d. estimation of the investment and operational cost of the projects to be undertaken by the
IWMS plan
e. some policy suggestion for the financing of the estimated cost together with other
supplementary policy measures
This report has been submitted to the Egyptian government for the review and revised
through a serious of joint works of the expert and Egyptian government officials for more feasible
solutions and detailed action plans.

Following chapter wiil be completed after the survey
Chapter2. Review of current systems and status of waste management
2.1 General situation: An overview
Since 1992 many efforts have been made to cope with the aggravating municipal waste
problems through establishing national strategy for the waste management and making master plans
for the implementation. In spite of all these efforts in the government as well as local governorates
levels, the harmful manifestation of the waste problem is still showing its manifesting trend. The
accumulated waste volume is in an increasing state and complain is reaching its peak. The authorities
concerned are spending its scarce resources just for cleaning job of the places where the voice is
high. Though experts and government officials in charge keep on insisting to introduce an Integrated
Solid Waste Management System, there does not seem to be any movement toward to this. All
government organizations are pre-occupied by the current issues of cleaning the worst regions just to
mitigate complains.
Evidently the government does not have any capacity room to spare for the management of
the municipal hazardous waste discharged with other municipal wastes. Egypt has legal frameworks
and systems for hazardous waste generated from the industrial sectors. But the municipal hazardous
waste such as FL wastes or thermometers, mercury battery cells, and other mercury containing
wastes are left never been controlled. The public awareness on the risk and harmful effects of
mercury contained waste is so low that no one attempts to have some measure for the appropriate
management of the waste. The worst case is observed at the fluorescent lamps manufacturing
factories. They produce a lot of defected goods and all these defected goods are reused at the site
without appropriate treatment of the mercury substances contained in the defected fluorescent lamps.
No regulation for this reusing process is enforced. Workers are exposed to daily contamination of the
mercury substance. Residents are also exposed to the same dangers without knowing.
2.2 Legal frameworks
1) legal status of mercury containing waste
FLW and other mercury containing municipal waste are not classified as hazardous waste
though mercury substance is classified as hazardous material. The FL wastes and other mercury
containing municipal waste are regarded as general municipal waste and collected and disposed
together with other municipal waste. There is no special regulation on its collection and disposal.

2) Organization in charge of Hazardous Municipal Wastes
Local Authorities (Governorates and districts. The Cairo Cleaning and Beautification Agency
-CCBA has been established recently) are responsible for cleansing of the assigned regions and
collect and dispose the municipal waste discharge in their jurisdictions. Many of the Local Authorities
have contracts with private service companies on the waste collection and disposal. The service cost
is paid out of the cleansing fund which is financed from the revenue of waste fees from the residents.
The waste fees are decided at 2% of rental value of household and commercial activities and issued
with the electricity bill. The problem is that many households do not pay the bill in time and
governorates are always in the short of fund resulting in delayed payment or even no payment to the
contract companies. The private companies just leave waste uncollected for the regions where the
payment is not made. The governorates do not have any financial sources to be spared to special
collection of treatment of the hazardous municipal waste.
3) Rules and standards for collection and disposal of the waste
list of related laws. plans, programs
law no 38(1967)
31(19700 129(1982) No.4(1994)
clauses about hazardous waste
general acts on solid wastes
responsibilities of generators/ LAs/ government(MOE, EEAA)
rules and guidelines to be complied by collectors/treaters (will be filled later)
2.3 Waste management policies and programs
1) The National Strategy and Action Plan (1992)
2) The National Strategy for Integrated Municipal Solid Waste Management (2000)
- A Framework for Action:
This plan has been reported and suggested but does not seem to be implemented. The
report recognizes the negative manifestation of the aggravating waste problems to suggest
an integrated management system for the municipal waste with gradual transition strategy
for the implementation of the action plan. This research does not cover the hazardous waste
contained in the municipal waste.
3) Capacity of governorates

all waste collection and disposal is in charge of governorates
budget is not enough
total municipalities budget for public cleansing are so meager that far short of needs.
Cairo LE 29 mil
Alexandria LE 21 mil
total annual expenditure on SWM 110-126mil LE
Financing sources available (will be filled later)
2.4 Infra structures
1) discharging practice
FL wastes are not discharged in separate from other non-hazardous municipal waste. It is
hard to find FL wastes unbroken, most of them are broken and discharged comingled with other
municipal waste. No discharging boxes or containers are available. Wastes are simply dumped to
streets and other empty spaces. People litter their waste out of houses, buses and cars without any
recognition. No regulation is made for these free littering. All of the regions of cities are occupied by
waste.
2) collection system
It is rarely observed private companies collect waste. Animal pulled carts collect recyclable
waste such as cans, papers, glasses, plastics. Waste towns called "Zaballeen" are formed near the
old Cairo districts to collect waste and separate recyclable waste to sell. People live together with
waste and make living out of the waste. They have trucks for transportation and most of the
separation work is done by hands. Their living condition is very poor and other people do not like them
near their residence even though they play a very important role of cleaning the cities. Cities are
maintaining some cleanness thank to these people. Nonetheless, they are not paid for their roles. The
government is planning to move them out of the city to the desert area. FL wastes and other
hazardous waste are not collected or separated by these people, either.
3) LAs capacity
Though Local Authorities have equipments, manpower for cleaning and collection of the
municipal waste, not enough for managing all the waste, budget is so meager that it is used for
cleaning severely accumulated regions occasionally. No capacity or budget for hazardous waste at all.

4) Survey of the private collection companies
equipments, manpower:
transfer stations
treatment facilities
disposal facilities: landfill, incineration, others
Private recycling/treatment companies
2.5 FLW management status: summary of survey
1) Sources and volumes
Industries
manufacturers of FLs
factories(thermometers)
Public sectors and building
universities,
schools
research institutes,
hospitals
Commercial sector
Buildings
Others
Residential areas
Cities/apartments
Rural areas
* estimation of accumulated quantity
2) discharge practice
Industries
Buildings
Houses
- revision of waste laws and acts are required to
enforce discharging duty of generators: sorting and put into boxes
* awareness of public/ LA officials/ governement officials/policy makers

3) collection
by local authorities (see diagram 1)
by private collectors
others
* barriers to efficient collection regulations
4) treatment/disposal
recycling at site
private recycling
Zaballeen
open dumping
others
restrictions/regulations/monitoring/penalties
by other laws and policies(water reserve/protection)
2.6 Problems
1) short of capacities
facilities
equipments
manpower
budget
other financial sources
2) Lack of separated collection system
3) low awareness
4) inappropriate organizational arrangement
responsibility sharing between central and local governments
between government and private(residents)
generators and government

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

Chapter 3. Integrated Management System for hazardous municipal waste
3.1 Basic principle
1) Why an integrated system?
An Integrated Solid Waste Management system is for coordinating various waste activities in
one framework of management system understanding the inter-relationship among various activities
making component activities complement one another. The UNEP international Environmental
Technology Center(1996) describes the importance of viewing solid waste management from an
integrated approach:
- Some problem can be solved more easily in combination with aspects of the waste
system than individually
- Adjustment to one area of the waste system can disrupt existing practice in other areas,
unless the changes are made in a coordinated manner
- Integration allows for capacity or resources to be completely used: economics of scale
for equipment or management infrastructure can often only be achieved when all of the
waste in a region is managed as part of a single system
- Public, private and informal sectors can be included in the waste management plan;
- An ISWM plan helps identify and select low cost alternatives: Some waste activities
cannot handle any charge, some will always be net expenses, while others may show a
profit. Without an ISWM plan, some revenue-producing activities are "skimmed off" and
treated as profitable, while activities related to maintenance of public health and safety
do not receive adequate funding and are managed insufficiently
The IWMS usually have clear and agreed hierarchy among various waste activities and
alternative management strategies. This hierarchy established helps to identify key elements of an
ISWM plan. The general waste hierarchy accepted by industrialized countries is comprised of the
following order.
- Reduce
- Reuse
- Recycle
- Recover by waste transformation through physical, biological, or chemical
processing(e.g. composting, incineration …)
- Landfill

The institutional frameworks are made of tools used to implement the general waste policies
and the institutional roles and responsibilities include the following; (i) policy/planning; (ii)
licensing/permitting; (iii) operations; (iv) monitoring; (v) enforcement; (vi) education; (vii) financing/cost
recovery and (viii) administration. Clear delineation of these roles and responsibilities is essential to
the successful implementation of the system. The IWMS rearranges all the policies and programs for
the sub-goals of source reduction, reuse, efficient collection, recycling, thermal recovery and disposal
by landfill or incineration for the best achievement of the goals by avoiding conflicts among different
policies, by choosing policy tools in harmony with other tools with a clear allocation of responsibilities
as well as cost sharing among different stakeholders: generators (consumers, residents, users),
producers, governments. It also re-organizes the various and uncontrolled collection and disposal
activities by different agents in a unified system to enhance its efficiency.
2) Basic principles in establishing an integrated system
The waste problem of Egypt seems to stem from the lack of or poor capacity of waste
management. There are no facilities for appropriate treatment of the hazardous waste and no infra
structures for efficient collection of hazardous waste separated from the nonhazardous waste. No
governorates have an organization or personnel for the collection of hazardous waste. No budget is
available.
The more basic cause is with the low awareness about significance of the risk of mercury
contamination by the non-industrial mercury contained waste. People are even ignorant of the fact
that some wastes contain mercury substances. So the first emphasis of policies should be put on how
to upgrade the awareness of the risk of mercury waste for public as well as policy making levels.
One of the effective ways to enhance awareness is let the people pay the cost. In general,
people are ignorant about public issues especially when it does not require economic gain or loss.
People are so keen to economic interest that when they are required to pay something, then they
become sensitive and pay attention to the public issues. Making people who are responsible for
environmental contamination pay the monetary cost of the contamination is based on the Polluter Pay
Principle (PPP). This principle is to internalize external cost of environmental contamination. People,
by consuming goods containing hazardous substance and discarding the goods after
consumption(use), unknowingly, generate hazardous waste resulting in external environmental cost to
other non-users. The PPP asks the polluter(hazardous waste generators) to pay the environmental
cost by the hazardous waste they discharge. So the consumers of hazardous goods must pay the
cost for collection and safe disposal of the hazardous waste. Being enforced to pay this cost, people
become well aware of the risks of hazardous waste and its external cost. This also make people

pursue means of reducing the harmful result either by refraining from over consumption of the good or
complying with the discharging practice in the process of searching for reducing their financial burden.
The poor management of waste also comes from the inefficiency of government
bureaucracy. The highly complicated rules and procedures for administrative routines and the
bureaucratic attitudes of government officials trying to comply with the rules and formats rather than
pursuing rationality in their daily jobs cause a chronicle inefficiency of waste management mainly by
public sector. The myopic views of policy makers worsen the situation by delaying the establishment
of legal and other policy arrangements for the introduction of an efficient integrated waste
management system. In order to break this long lived inefficiency in the government sector, an
aggressive participation of private participation is inevitable.
So the Integrated System suggested here for the proper management of hazardous
municipal waste should be formulated on the two basic pillars of PPP and Commercialization
principle. First, government must establish PPP in waste management. Clear identification of
polluters, agents responsible for the generation of waste should be made by legal arrangement. For
the hazardous waste, the dischargers who had used the goods becoming waste are primary polluters.
In the case of mercury containing waste, consumers of the FLs and other mercury containing goods
are the agents responsible for the waste. For defected FLs, manufacturers are responsible for the
waste management. So these agents should pay all the cost for collection and treatment. Local
authorities often share the responsibilities with consumers, since local authorities responsible for the
waste in their jurisdictions. Local authorities can collect and treat the waste and the cost paid by local
authorities is born by consumers with increased tax burden or goods price. Roles and responsibilities
may be allocated among the agents different from the polluting responsibilities for the efficient
management.
stakeholders roles/responsibilities cost payment
Consumers
(users)
households
public sectors
discharge
all the cost
paying the tax
paying price
commercial self collection and treatment
all the cost paying the
collectors and treaters
Producers
(manufacturers)
defected goodsself collection and treatment all the cost
used goods EPR responsibility
share cost with consumers
and governments
Local authorities collection and treatment
pay the private companies in
contract
collect waste fees from
residents
Central government
establish infra-structure
subsidies to local authorities
out of general tax or
special waste tax
It is desirable all the activities for physical collection and treatment of the waste be
undertaken by private business on the commercial profit basis. Private companies are keen to profits

and to costs and will find most efficient ways in all the stages of waste management, collection,
transportation, treatment, and final disposal. Government should make the environment for maximum
participation of private enterprise in the waste management business. Various projects and programs
should be introduced to induce the private investment from domestic as well as foreign sources.
Government should provide a clear set of rules for the business. Private funds must be induced with a
firm guarantee for the recovery of investment funds which can be made by contracts between
governments and private companies on the ways of collecting fees and subsidies in the case of not
reaching the proposed level of revenue. Private operators of the treatment facilities or transporters of
the waste should be guaranteed with fees enough for the actual cost. For these contracts,
government should establish standard contract formats and procedures. Government also shows a
stable and sustainable business environment with long term master plans for waste policies.
And the government must confine its roles to formulation and enforcement of the standards
and rules to be complied in the whole procedures of collection, transportation and treatment of
hazardous waste and monitoring and supervision of the activities. Government should implement
various programs to upgrade public awareness and conduct survey and statistics-related projects.
And Local governorates should be given monitoring and supervision responsibilities for the activities
taken in their jurisdiction, and some limited work of collection.
3.2 prerequisite
1) establishing an IWMS for municipal waste
Here FLW and other mercury containing waste are the hazardous waste from municipal
waste(municipal hazardous waste) and are discharged and collected in the same region and usually
in the same practice as the non-hazardous waste. The management system of the municipal
hazardous waste, therefore, should be established under the umbrella of the management system of
the all the municipal waste, and in harmony with the other municipal waste management. This means
there must be an integrated management system for the all the municipal waste established, before
an integrated municipal hazardous waste management system can be established. If the municipal
waste is not managed systematically in an integrated approach, the municipal hazardous waste
cannot be effectively managed, even though we introduce an integrated management system for the
hazardous waste. So a rough sketch of an integrated waste management system for the general
municipal waste is provided, here.
An integrated approach to the management of municipal wastes requires a set of alternative
management strategies toward a minimization goal; minimization of waste volume and minimization of
the waste cost. Alternative management strategies include various collection system and
disposal/treatment methods and an appropriate combination of collection and treatment method is

chosen for a certain waste from a certain source. So an integrated waste management system is
composed of different sets of discharging, collection, transportation, recycling and other disposal
methods for different kinds of wastes. The chosen approach of management strategy for certain
waste must be the best one available, in terms of effectiveness and efficiency. For this purpose, there
must a hierarchy clearly agreed upon among the members of the society, in choosing an approach out
of alternative collection and treatment methods for a certain waste.
The hierarchy is for the best fulfillment of the goal of minimization. The hierarchy agreed in
most societies are; first reduction at source, secondly, reuse, thirdly recycling(material first and then
thermal) and finally safe and sanitary disposal either by incineration or landfill. The integrated
management system suggested to be suitable for Egyptian situation and environment, therefore, must
have the same hierarchy; reduction, reuse, recycling and sanitary disposal. The municipal waste are
classified into several groups; Food and organic(garden) waste, packaging waste, e-waste, hazardous
waste, other residual garbage. For different groups different strategies should be chosen in
satisfaction of the hierarchy principle for the best achievement of minimization goal.
The integrated management also includes integration of all efforts of all the members of the
society. Roles and responsibility are allocated and shared among all the stakeholders for the
maximum participation and effective and efficient role playing of each member. A basic principle for
drawing maximum participation is the PPP. An appropriate responsibility sharing is made by an
agreed upon cost sharing based on this Polluters Pay principle. Now most countries are shifting the
responsibility for municipal waste from sole responsibility of local governments to shared responsibility
system among consumers(dischargers, generators), producers and governments(Local and central).
This shift increases the awareness of the public other than local authorities about the significance of
waste issues leading to more active participation of the waste reduction programs in pursuing the
saving of their financial burden. Producers are also become more concerned about waste of their
products, leading to various efforts to reduce waste volume and easy recycling of their waste. This
also increases the entry of private funds and enterprises in the waste business resulting in an
enhanced efficiency of waste management contributing to the waste cost minimization goal. Under the
integrated system, government role is confined to presetting of the rules and standards for the
appropriate treatment of the waste, legislation for the implementation of the rules, and enforcement of
the laws and acts, design of collection scheme for the best service to residents and least cost of
collection, arrangement of roles and responsibilities among all the members of the society, and
construction of the infrastructures. Consumers are assigned the general duties to reduce the waste
volume they generate in one way or another, comply with the discharging practice, and finally bear all
the burden of waste cost through tax increase or price increase. Producers are assigned duties to
refrain from excess packages, to develop environment friendly goods with design for environment,
material and structure improvement for easier recycling, redesign of logistic routes considering waste
collection and recovery, and share of waste cost. The role of producers is usually enforced by

implementing EPR system for packaging waste and e-waste and some hazardous waste. Consumers’
responsibilities are encouraged by some incentives such as volume rate waste fee system and
campaigns for upgrading their awareness. Followings are the roles of each stakeholder and some
policy measures for the maximum participation.
stakeholders responsibilities regulation incentives
consumers
reduce over consumption
prolonged use
increased reuse
volume rate of waste fee
consumption tax
2nd hand market
refurbished goods
separated discharge of
recyclable waste
exemption of waste fee
recycling center
mileage and exchange
program
producers
change of goods for easier
recycling
Eco-assurance
active participation of recycling EPR
local authorities
efficient collection scheme
financial burden for
collection
financial and
administrative
assistance
monitor and supervision general responsibility
guidelines
joint supervision
2) An IWMS for e-waste
Institutional frameworks for fluorescent lamp waste management are the same tools used to
implement e-waste management policy, since fluorescent lamps are electric/electronic products and
their producers are subject to same regulation for other electric and electronic industries. And before
introducing IWMS for fluorescent lamp waste, an efficient management system for all e-waste should
be established. So here is provided a rough idea of an integrated management system for e-waste.
Most e-wastes have some valuable materials and can easily be recycled with commercial
profits. With the soaring prices of low materials the so called urban mining is popular among
government officials as well as private business. The private business can instantly make profit out of
the e-waste recycling business, provided that enough quantity of waste are collected. And this
collection anticipated to be performed by governments, at least in the public sector, though actual
collection can be undertaken by commercial business. Government must establish an infra structure
for efficient and stable collection and supply of e-waste.
The infrastructures include legal framework controlling discharging practice and assigning
collection duties for certain economic agents, like free acceptance of collection of used e-goods, EPR,
consumer-deposit, exchange program by retailers, and operation of physical facilities for collection
such as collection centers, bring back centers, and various assistance programs for recycling
industries.

3.3 Establishing PPP and responsibility allocation
1) Different responsibility sharing for different kinds of waste
Before establishing integrated management system, mercury containing hazardous wastes
should be classified into two groups; defected goods from manufacturers and post-consumption
waste. The waste generator of the defected goods are manufacturers of fluorescent lamps and other
mercury containing goods and those of post-consumption waste are users of the goods. The users
are classified into two groups of big users and households. Big users are again composed of two
groups; commercial users for commercial buildings, factories, big retail shops, entertainment facilities
and other business sites and public or institutional users of hospitals, universities and schools,
research institutes, government buildings. All the users big or small, are all generators of hazardous
waste and must be responsible for their waste. In sharing responsibilities among stakeholders,
however, big commercial users should be treated different from the other users. Commercial users
are in the good position to transfer their financial burden to other economic agents of consumers or
their previous stage producers. In addition most of them have some control for the efficient collection
or treatment of their waste in choosing contract companies because of large bulk of the waste and
control of discharging practice, while households and small users do not enjoy such position. Public
and institutional users can be treated like commercial big users because they can enjoy the same
position but their activities are under the control of government so can be subject to government direct
control and can be treated differently.
2) responsibility for defected FLs
The responsibility for appropriate management of defected goods is assigned to
manufacturers of the goods. The producers should collect and treat their defected goods with their
own expenses according to the rules and standards in safe and with no impact on environment and
people. They can entrust professional commercial business with their job. The entrusted private
companies must have been licensed for their business with facilities and manpower required.
3) Responsibility for post consumption waste from commercial sectors
The owners of the buildings or business sites are responsible for the management of their
waste. They must collect and treat their waste with their own expenses, according to the rules and
standards, in safe and no impact on environment and people. They can entrust professional

commercial business with their job. The entrusted private companies must have licenses for their
business activities with facilities and manpower required.
4) Responsibility for the post consumption waste from public sectors
For these waste local authorities are responsible for collection and treatment. LAs must establish an
efficient and safe collection scheme and operate facilities. Of course LAs can entrust private
companies with the collection and/or treatment work. LAs pay the cost out of the budget or cleansing
fund made by waste fees from the residents.
5) Responsibility for the post consumption waste from households and residential areas
For these LAs are primarily responsible for the collection and treatment. But LAs can assign
additional responsibility for residents to comply with the discharging practice, with penalty in case of
non compliance. LAs can have campaign or events to collect rarely generated hazardous waste such
as Mercury cells, thermometers which provides LAs with enough volume of waste for a separate
treatment
3.4 Privatization and Commercial operation of facilities for collection and treatment
The second pillar supporting IWMS is an active participation of private fund and enterprises
in the collection and treatment business. There are two realistic constraints for inducing private funds
and enterprises into the waste business; (i) not enough incentives guaranteeing commercial profit and
stability of business environment and (ii) a supervisory system for business activities and practice
ensuring their compliance with all the regulations and so acceptance by public for their satisfaction.
Two arrangements are in need, for the overcome of these constraints; the first one is
provision of a stable and sustainable business environment and enough incentives for private
participation and second is establishment of a monitoring and supervision mechanism legally bounded
and equipped with effective enforcement measures.
Private fund and enterprises are very keen to profits and the business environment. If the
environment is not seen stable and so recovery of investment is not clearly foreseen, the private
participation would be hesitated. Most of all the attitude of government must be decisive and all policy
formulation and implementation must have long time horizon, much longer than private business
plans. Markets for environment industry are created and sustained by environmental regulation, so all
the environmental policies must have clear goals and missions to be pursued for a long time.
Otherwise the markets cannot show a sustainable development in the future. For all these
government show it's firm position by announcing a long term master plan. Measures for fair

competition among the private enterprises through strict licensing are also in need. Strictly enforced
and regular monitoring for ensuring appropriate collection and treatment will contributes to preventing
enterprises' easy entry and exit for short run profit destroying the market.
For the initial stage of the plan, government can initiate business activities by constructing
facilities and lease them to private operators. A continuous flow of cash should be secured for this
lease enough for financing the daily operation. As the profitably become visible government can
induce private funds which invests for the construction of facilities and recover the cost out of the
revenues from the operation of the facilities. Government can initiate private funds for the waste
business by introducing tax exemptions and other privileges.
3.5 Collection system: Dual system
1) a separated collection system from the general municipal waste collection.
As mentioned above, municipal waste is discharged according to separated discharging
practice into several categories. Food and organic waste are discharged into special food waste
containers and collected by composters. Recyclable waste are sorted into several kinds and
discharged into different bins; paper, cans, glass bottles, and are collected by recyclers. E-wastes are
collected by private recyclers/collectors or EPR producers(or entrusted recyclers or their joint
organization, PRO). FL wastes and other mercury containing waste should be discharged by users to
special containers designed for safe storage and transportation and placed in the designated area
near sources. Different sources have different modes of discharge and collection of the same waste.
2) Defected goods from manufacturers
Generators(FL manufacturers) should collect their waste in the safe boxes, the specification
will be made by EEAA and announced with other rules and guidelines. They transport the waste to the
facility with their own expenses. Facility operators or the entrusted transporters can transport on
contract. The transportation cost will be paid by manufacturers. Manufacturers also pay the treatment
cost. The standard cost will be announced by EEAA(appendix) Equipments for the transportation
must comply with the specifications and rules and guidelines to be announced by EEAA.
3) FL waste from big users
- Commercial sources
Users must keep collection boxes with government specification within their business sites
and transport them to facilities or make contract for the transportation. They must comply with the

collection methods and rules required by the transporters or facility operators in case of self
transportation
- Public sources
Users must keep collection boxes within their buildings and sites. Let the collectors collect
the boxes providing easy access and other convenience for collection workers. These collections are
made by local authorities or entrusted private collectors.
4) FL waste from small users
- Collection boxes
Local authorities must designate places for discharge and place boxes or other containers
which can be manage for preventing breaks and must have a monitoring system for appropriate
discharge and safe collection. Residents must comply with the local authorities’ rules and guidelines.
- Collection centers
Governorates can operate collection centers where those who bring the used lamps are
rewarded in various ways, cash, saving account, mileage, coupons for exchangeable with some
goods, even lottery. Some light penalty or fines can be replaced with the bring-back mileages. Private
companies also can operate collection centers where some incentives are given to those who bring
the waste. Operation cost can be subsidized by governments and/or by manufacturers. Retailers or
wholesalers can also operate collection centers sometimes with some consumer deposit system or an
exchange program which consumer can buy new one in exchange of old one. Automatic collection
using vending machine can be installed where people visit often such as parks, rest areas. The
machine rewards those who input FL wastes into the machine by giving coupons, or accumulating
mileage for future spending.

Diagram2. A schematic layout of collection system
5) Mercury cells, thermometers can be collected through events or campaign at schools
or other residents meetings
* rules and standards for collection and transportation and specifications of collection box :
appendices 1. will be provided by unit suppliers.
3.6 establishing a stable financing system
1) establishing PPP
Transferring responsibilities for municipal waste which have long been understood as one of
the basic services of LAs from government(tax payers) to generators(consumers and producers) is
visible throughout the world. This responsibility transferring is based on the PPP. The PPP providing

generators with incentives for reduction is a favorite menu of the policy makers in developed as well
as developing countries, since reduction is the primary sub-goal of the integrated waste management
systems. Korea, for an instance, has introduced the volume rate waste fee system which differentiates
the fees according to volume. The system is evaluated very successful in reducing overall waste
volume. Likewise PPP is necessary for the hazardous waste just to encourage efforts to reduce waste
volume. PPP can easily be applied to hazardous waste where the generators are clear.
For the successful implementation of the integrated hazardous waste management system,
PPP should be established in both general municipal waste and hazardous waste. The PPP realized
by differentiated waste fee scheme according to waste volume can contribute to separate discharge
or collection of hazardous waste when supplemented with no charge rule for the separated discharge
of certain waste such as recyclable waste, e-waste, and hazardous waste. The exemption of waste
fee gives people with incentives for separation of those wastes from the general waste to save waste
fee payment.
PPP in the hazardous waste is realized by making generators bear all the cost of collection,
transportation and treatment either by direct work or payment to the agents. All the cost are
determined by private contract basis depending on the terms and conditions but government can
provide a guideline for the decision of the fees. The generators, however, can have different scopes
depending on kinds and source. Manufacturers are generators for the defected goods. Big users are
generators for the waste from commercial sectors. Local authorities are regarded as generators for
the waste from public sectors and households on behalf of actual generators.
2) Alternative financing schemes for government cost
Government (or local authorities) must pay all the cost for the management of the FL wastes
except for defected goods and waste by big commercial users. This government payment can be
financed by various ways. Here are some examples.
A. Government financing
Investment funds for the construction of treatment facilities should be financed out of
government budget in principle. But in most cases developing country government do not have
enough budgets for the investment cost. Sometimes aid from international organizations or foreign
governments may be available, but these aids or grants are limited and mostly restricted to small pilot
facilities. Government needs stable financing sources other than foreign aids. Introducing an objective
tax or raising general tax rate can easily attempted but very often subjected to strong objections from
taxpayers and difficult to have congress consent.

As one of the means securing financial sources for government investment plans, invitation
programs for private funds are often recommended. If with enough budget, government can construct
the facility out of government budget and lease the facilities to private enterprises paying the
operation cost. These cases are not common with most developing countries. The more general type
of private fund invitation programs are let private funds invest their own money for the construction of
facility and give rights or issue licenses to operate the facility collecting service charges from users.
These rights are guaranteed until they can recover all the investment cost with some profit and in
case of loss(operation cost exceeds the fee revenue) government subsidize the loss. The participating
private funds are safe in doing business with exclusive operation rights sometimes monopoly power
without any competitors, and securing minimum profit in addition to recovery of investment money.
B. special waste charge
For the hazardous waste extra cost is required for their special collection and treatment
separated from general municipal waste, which are financed by waste fees and or local budgets. For
these extra costs, government levies product charges such as special waste charges. The special
waste charges can be levied to all mercury containing goods (fluorescent lamps, thermometers,
mercury battery cells ...) The revenue collected from this charge is used to finance the collection and
treatment work by local authorities being subsidized by central government or paying the directly
private operators and collectors.
C. Deposit-refund system
Producers must deposit money for the recycling cost of their product waste in advance. The
deposited money is refunded for the recycled quantity by producers. This system provides the
government enough financial source for the construction of infra structures and treatment of the waste
on behalf of producers.
D. EPR system
Producers are assigned recycling obligations of their product waste with mandated recycling
rate or quantity and penalized for the non compliance. Recycling charge is levied for the not-recycled
quantity. So the producers pay the recycling cost assisting the recycling business. The deposit-refund
system and EPR system should encourage producers to be engaged in product change efforts, such
as changed structures and materials of their products in favor of easy recycling. These strategy
changes are expected to be undertaken by enterprises in the process of pursuing for reducing
recycling cost.

Diagram 2. financing under EPR scheme
3.7 supplementary measures
1) Government inventory programs
There is needed an organization in charge of survey and statistics work. It should conduct
regular survey and establish and maintain a data base for status related statistics including list of
sources, generation volumes, collected volume, treated volume, and other statistics about industries
such as number of enterprises, sizes, capacity, performance, equipments, facilities, and manpower.
The organization can be a public agency or a private association of producers or recycling industries.
The organization must be supported by government budget and can be partly subsidized by
concerning producers and/or recycling industries.
2) Planning and implementation organization
There must be a government organization or government section in charge of managing the
system by formulating policies and programs, and implementation plans, set rules and standards and
undertake overall supervision of the enforcement organization, local authorities and obliged
producers. There also must be an organization in charge of enforcement. The organization accept

reports from producers and recyclers to check mis-maneuver, and confirm the quantity recycled with
confirming if the rules and procedures are complied in performing the collection and recycling jobs.
There must be a monitoring system for the reports of producers and waste generation and recycling
business.
3) Education and public campaign
Upgrading the public awareness about the risk to health and environment by the
inappropriate treatment of FL wastes is absolutely required for the maximum participation of public in
the management system. Strict compliance of discharging practice is critical to minimizing the
contamination risk from the leaks of Mercury into air and proper collection of waste, which greatly
contributes to reducing recycling cost. The upgrading program can effectively implemented by school
education programs and development of classes and education materials and supply of instructors
should be performed by government. Public campaign by central government through TV, media, ads
and commercials are also seen effective to draw peoples' attention to realize the significance and
events such as collection day of thermometers, batteries by local governments, or central government
and by residents meeting, or NGOs.

Chapter4. Design of EPR system
4.1 Concept and background
1) concept
EPR(Extended Producer Responsibility) is to transfer responsibilities for waste from local
authorities to producers, from tax payers to waste generators. The scope of producers' responsibility
is expanded from production of goods, sales and liability for the consumption period to the
management of their products after consumption. EPR places the responsibility upon the
manufactures to reduce the environmental impacts of their product at each stage of the products life
cycle- that is from the time the raw materials are extracted, produced and distributed through the end
use and disposal phases. Producers must collect and recycle the goods they sold after buyers discard
them. When consumers discard the goods they become waste tentatively but become raw materials
or new goods, so the waste to be recycled is defined as post consumption not waste. Under this
system the ownership of the goods are not transferred to consumers at the sales point. Consumers
are understood to lease the goods and return the goods after consumption to producers.
2) Why producers?
Why producers should have this expanded responsibility? It is only because producers are in
a best position to promote recycling. (i) Producers decide the materials and structure of their goods
which have a great impact on the recyclability of the goods. By adopting DfE producers can change
materials and structures of their goods for easier recycling. (upstream control) (ii) Producers can
provide recyclers with information for recycling job by disclosing the structures, kinds of materials
used and other features and properties. of their products. (iii) Producers can provide an efficient
logistic route for the post consumption by making use of the distribution channel of their products. (iv)
Producers can contribute to creating and expanding markets for the recycled goods being big
consumers of recycled materials. (v) Producers are in the best position transferring the recycling cost
to other agents, eventually to consumers. (vi) Finally, and most importantly producers are responsible
for the over consumption of modern consumers(and so excessive waste generation) as they provoke
people to buy with aggressive sales promotion strategies through massive ads and commercials.
4.2 who are producers?
EPR does not consider only the manufacturers accountable for the environmental impacts;
this responsibility is extended to all those involved in the product chain from manufacturers, suppliers,

retailers, consumers and disposers of the products. Sometimes EPR is called as SPR (shared
producers responsibility). In England, sharing of the responsibilities all the agents in the same product
chain is explicitly stipulated, while in the rest of the countries the sharing is left to self reallocation of
the agents themselves are given different share of recycling obligations.
There are two groups of waste subject to EPR system. Packaging waste and durable goods
waste. For packaging waste bottlers(fillers) using the packages are the producers responsible.
Domestic fillers and importers are included. For durables waste, manufacturers and importers of the
durables are producers. Manufacturers and importers are responsible producers in the case of
fluorescent lamps and other mercury containing waste.
Manufacturers, importers, wholesalers and retailers, all the agents in the product chain are
responsible and responsibilities are shared among them. In English version obliged recycling rates
are assigned to all the agents. Each agent is assigned its own target rate. In other European and
Korean versions, one agent with greatest market power is selected as prime producers who are
assigned legal duty. The prime producers are expected to reallocate their burden among all the
agents in the product chain by transfer mechanism. The brand name owners are believed to have the
greatest market power and selected as the prime producers. In Japanese version, local authorities are
included among the agents to share the burden. Producers are responsible only for the collected
quantity by local authorities.
4.3 Duties and responsibilities of producers
1) manufacturers/importers
Their responsibilities are two folds; responsibilities in the stage of production and in the stage
of post consumption. Producers, in the stage of production, must try to change the structures and
materials through DfE( design for environment), for easier recycling, less use of packages, extended
longevity, and strengthened durability, and must disclose the product information for the use of
recyclers. Producers, in the phase of post-consumption, must recover their post consumption
products to the mandate recycling target. The target is decided as the rate of the sales volume.
Producers, for the recycling obligations, must report sales volume, submit recycling plan with their
facilities and manpower showing their capacity or contracts with licensed recycling companies, and
report the result(completion of obligation), In case of non-compliance or less compliance must pay the
penalty(recycling charges).
2) wholesalers and retailers

Often wholesalers are assigned to collect the post-consumption by running collection center
or simply accept the used goods collected by retailers. Retailers are assigned to collect post
consumption for free on consumers request. For FLW case, retailers can be forced to run an
exchange program under which retailers can sell new lamps in exchange of used ones. Producers
and wholesalers retailers all should try to promote return of the used lamps introducing incentive
programs
4.5 Methods of complying with recycling obligations
Producers must be allowed to entrust other recyclers with their recycling jobs, since most
producers do not have facilities or other means to recycle their post-consumption and are generally
given options in complying with their recycling obligations; self recycling or consigning., And most
countries have a system for joint recycling of producers, called PRO (Producers Responsibility
organization). The PRO is a voluntary organization of EPR producers to meet the obligations together.
1) Self recycling
Producers, for self recycling, must have own collection, transportation and treatment facilities
and should have license for those work with enough manpower and equipments. They must report on
their plans and facilities showing their capacity and are subject to pre-examination by government
authorities. They must report the result and be examined the achievements and compliances with the
rules and procedures in their all the stages of recycling jobs.
2) entrusting
Running a recycling business is not regulated provided that the recycling methods and
process satisfy the rules and do not make any harm to people or environment. The recycling business
which is entrusted with the recycling obligations by producers must have licenses from the
government. I issuing licenses, government must confirm their ability to recycle the entrusted quantity.
Government pre announce the conditions for obtaining recycling business licenses. The conditions
include equipments and manpower for collection, recycling facilities and units for the kind of
technology they adopt, and other facilities and equipments. Producers can consign their duties only to
the licensed recycling companies. Producers must submit recycling plan with contracts with the
licensed recycling company. Producers report the result with certificates of recycling by the contracted
company. Producers are responsible not only for the non-compliance or un-recycled post
consumption but also for the cheating, fraud, or illegal maneuver by the consigned company.

3) join a PRO(Producers responsibility organization)
Producers can organize their own association to perform their obligations jointly. Government
issue permit the associations to do all the activities for meeting the EPR obligations on behalf of
member producers. The PRO make all the reports, make contract for the recycling job with the
licensed recycling companies, collect membership fees, pay the recycling cost and responsible for all
the recycling performance and the recycling activities. Producers are exempted from all the
obligations by joining a PRO. Producers do not make any reports and are not responsible for the non
or less recycling than the mandated target rate or any kinds of mis-maneuvers by PRO or its contract
companies.
4.6 Recycling targets
Government decides total quantity to be recycled for the target year, considering the
capacities of collection agents, Local authorities, private companies and other collection agents and
the capacity of recycling facilities. This target quantity is converted into target rate of recycling by
dividing the target quantity by estimated waste volume. Waste volume is estimated as the same as
the sales volume for the case of packaging waste and calculated as some percentage of sales volume
considering the average year of use. The target volume of recycling of fluorescent lamps waste will be
estimated the sales volume and the average year of use based on the survey result. (appendix)
Individual producers are given target quantity by multiplying the target rate to their sales volume
(generally the sales volume of the previous year). Government usually operates a meeting of
producers and other stakeholders to decide the target rate of recycling for each product.
4.7 Penalty for noncompliance
Producers and/or PROs are levied penalty for the case of non or less compliances of the
obligations. Fine, generally called recycling charges, is decided at the level for government doing the
recycling of the waste. The unit recycling cost is estimated and pre announced as standard recycling
cost by government (appendix) Governments run a banking system issuing credit for the excess
recycling over the obligated quantity. Producers can use the excess recycling quantity over obligation
for the next years’ obligation.
4. 8 Exemption of obligations
In principal al the producers should be given recycling duties in proportion to their sales or
waste generation. But for small companies it may be a great burden financially as well as physically.

Sometimes it may be a severe disturbance or obstacle to normal business operation, and their
recycling volume is so small that nearly negligible contribution to overall recycling target. In many
cases of small business, the administrative cost exceeds the benefit of recycling. In addition,
government does not have enough manpower to control and monitor all the small enterprises. There
must be some exemption of duties. Most countries exempt small companies with sales less than
standard amount and/or sales volume less than standard volume from the recycling obligations. The
exemption criteria for fluorescent lamps waste will be decided later in the third phase when the EPR is
actually implemented, considering the relative weights of small companies in the total waste volume
and manpower in charge of the administrative job.

Chapter5. Implementation plan for establishing IWMS for mercury containing
waste
5.1 Goal
The final goal of this implementation plan is to develop the capacity of Egypt to deal with
mercury containing waste by achieving sub goals of (i) upgrading public awareness, (ii) construction
of recycling facilities and other infra structures for collection and transportation of full collection and
treatment of mercury contained waste from all sources, (iii) establishing a stable financing system
based on the polluters pay principal, and (iv) full development of waste industry where private
enterprises run business for commercial profit by 2020. Ideally governorates will have recycling
facilities (private or public) in their regions and developed their own efficient collection system by 2020
and most of the actual activities of collection and treatment will be undertaken by private companies in
contract with local authorities or independently for purely commercial profit. All these goals can not be
achieved in one time and takes a very long time, so here a gradual or phase-wise development
strategy is recommended.
5.2 Phase-wise strategy of implementation
The whole plan can better be implemented in three phase of starting and preparation,
expansion, and development. The first phase is the completion of the KOICA project for the normal
operation of the pilot facility to be constructed by the project with all the legal and other administrative
preparations. In the second phase Egypt make its own master plan for expansion of the scope of
waste and sources and implement it with own ability by constructing facilities and other infra
structures out of its own sources. Financing will be made out of private funds by making an
environment for private business. In the third phase all the systems and infra structures are
established to cover all the waste from all the sources. By this time the EPR system is completed and
commercial business will take care of most of the collection and treatment of hazardous waste.
1) 1st phase: 2010-2012: KOICA PROJECT period
KOICA initiated preparation for introducing an IWMS for mercury containing waste is
undertaken during this first period. The main goal is to build the capacity of Egypt government for self
management of the mercury containing waste. For this purpose, a professional consultancy for
designing an integrated management system for municipal hazardous waste, manpower training
services are provided by KOICA with the construction of a pilot facility for FLW recycling. By the end of
the 1st period, the Egyptian government must have a design of integrated management system for

the municipal hazardous waste, an implementation plan which includes construction plan of
infrastructures(number and capacities of facilities) for the waste management, financing plan for the
investment and operational cost, manpower training plan and program. Tasks to be undertaken are (i)
survey on the status of the mercury containing hazardous waste management, (ii) design of an
integrated waste management system for mercury containing hazardous waste (iii) making a master
plan for introducing the IWMS, (iv) construction and operation of the pilot facility by KOICA project.
The scope of waste is confined to defected fluorescent lamp goods generated by manufacturers.
Expansion of the scope of waste can be considered after the normal operation of the pilot facility and
after construction of new facilities and establishing collection scheme in the target governorate
area/region.
2) 2nd phase: 2013-2017
In this following phase the Egyptian society must establish a sound foundation for the IWMS
with government initiation. The government people trained by the KOICA program and government
agencies which have experience of facility operation will initiate the business and promote private
participation in the field of hazardous waste collection and treatment business. The enhanced public
awareness in the 1st phase will contribute to establishing a culture in favor of recycling putting
pressures on assigning producers recycling responsibility making the government can have legislative
framework for introducing a responsibility sharing system like EPR or other financing scheme.
With the new financial sources government can construct infra structures and induce private funds for
the construction of facilities. Commercial operation of the facilities is popularized governorates assist
the private business by making contract and ensuring profit, and/or providing spaces and equipments
for easy collection. The scope of waste is expanded to used old lamps by big users from commercial
sectors of commercial buildings, factories, business sites.
Tasks to undertaken in the second phase are (i) Construction of facilities in major
governorates regions, cities and districts. (ii) Establishing a nation-wide unified collection system
ideally by private companies, (iii) Establish an environment for private business
3) 3rd phase: 2018-
This phase completes all the missions. All the infra structures are built and all the systems
are completed to cover all the mercury containing waste from all the sources. Most collection and
treatment are conducted by private enterprises on the commercial profit basis. an EPR system is
completely implemented to assign all the producers of mercury containing goods responsibilities for
recycling and other activities. A stable financing scheme is established and financial assistance by
producers are made for the commercial operation of collection and treatment works. All the

governorates will have a nation-wide unified collection system, various collection centers,
transportation routes and modes, treatment facilities with enough capacity to treat all the collected
volume, supported by legal frameworks and manpower supplying system.
The scope of waste will be expanded to cover all mercury containing waste from all sources. Tasks to
be completed in this phase are (i) Responsibility sharing among LAs and all the agents related with
waste generation, (ii) legal and socio-economic settlement of the responsibility sharing, (iii) a full
privatization of the hazardous waste business.
Following table shows goals and strategies for each phase.
1st phase 2nd phase 3rd phase
2010 2011 2012 2013 2014 2015 2016 2017 2018-2020
waste defected goods post- consumption waste
sources manufacturers
commercial
big users
public big users households
regions all nations Cairo
Greater
Cairo
Greater Cairo/Big cities Cities
infrastructures pilot facility
- new facility
(private)
- collection center
- new facilities
(private/public)
- new facilities
(public)
legal and
administrative
systems
- regulating manufacturers
- regulations for recycling
activities
- organization in charge of
control and supervision
-discharging
practice
financing
system
- establish PPP
- incentive programs
for private funds
- volume rate waste fee
- exemption for separated
waste
- EPR
- consumer deposit
- exchange program
5.3 Construction plan of Infrastructures
1) Construction of FLW recycling facilities
to be completed after survey completed
year
Number of
units
waste treated capacity sources
2010 1 defected goods manufactures in Cairo region
2012 1 defected goods all manufactures
used old lamps
commercial sectors in Great Cairo
region
commercial sectors in all big cities
public sectors
all the sources, all the regions
other mercury waste

5.4 Estimation of cost and financing (to be completed after survey)
year
Number of
units
investment cost operation cost financing sources
2010 1 manufactures
2012 1 manufactures
2013 commercial users
2014 commercial
2015
Local authorities, fund from EPR
(producers)
2016
2017
2018
5.5 programs for upgrading public awareness
school education: distribution of education materials, special train of teachers
public campaign: media programs , public advertisement
distribution of phamplets and other materials
to be completed after discussions with Egyptian government officials
5.6 Manpower supply plan
making and implementation training plan
establish institutes
develop training programs and materials
to be completed after discussions with Egyptian government officials
5.7 post plan
The basic plan for reducing the environmental contamination by mercury waste is
replacement of the mercury containing goods with non-mercury goods. For mercury battery cells
already other substitutes are developed so some program for discouraging the use and production of
mercury battery cells is recommended. Simply the use and production can be banned. Most gages
and gadgets using mercury can be substituted with other non -hazardous goods. Legislative
measures banning or regulating the use and production can be applied in accordance of technological
development. For fluorescent lamps, LED can be a good alternative. Because of the high prices of the
LED products, enforced substitution is not feasible. Efforts to down the manufacturing cost by massive

purchase by government sector through a renewal plan of public buildings and schools should be
implemented with some subsidy programs for the domestic manufacturers

Chapter 6. Action plan for the 1st
phase
6.1 Legal framework
1) reclassification of waste
It is needed to define defected fluorescent lamps as industrial hazardous waste and assign
manufacturers responsibility for management of the waste. Manufacturers must report the volume of
waste, and treat in the regulations for collection and treatment of the mercury contained waste.
Used old fluorescent lamps and other mercury containing waste from non-industrial sector are
classified as hazardous municipal waste subject to special regulation in dealing with the waste. The
other mercury containing wastes are mercury battery cells, thermometers, barometers, rectifier and
catalysts.
2) assignment of responsibilities
Manufacturers are assigned responsibility for self treatment of the defected fluorescent lamps
with own expenses. In case of legislation is not feasible within the time period, voluntary agreement
between manufacturers and government (EEAA) can be an alternative. The voluntary agreements are
backed by some threatening for strengthened legislation in the future. Local authorities, governorates
or CEO of districts and cities should be given responsibility to collect the old lamps separate from
other municipal waste and take measures for separate discharge and collection. They are encouraged
to rune incentive programs for commercial operation of facilities and collection business. This also can
be implemented by voluntary agreements between ministry of environment and LAs before any
legislation.
3) government organization
There is needed a government organization for overall control and administration of mercury
containing waste. According to current EEAA organization, section for hazardous substances and
waste is the best section for those affairs. It is in charge of making rules and standards for overall
control of the waste activities by making new laws, revising existing laws and acts, making conditions
for licensing waste treatment facilities and operating business, regulations to be complied in
undertaking the waste collection, transportation, treatment, and disposal activities.
There must be organized an independent government agency under the hazardous
substances and waste sector which will be in charge of supervision of the fluorescent lamp waste
recycling facility operation. The agency will make operational guidelines, emergency plans, and

analyze the recycling cost to decide standard waste treatment fees which will be used as a refenece
for the contract between operators and manufacturers.
4) regulations for recycling activities
- discharging practice
All the users of fluorescent lamps should separate used lamps from other waste and garbage
and place them unbroken at the containers or boxes with cautions not to break. Any intended
breakage of lamps are penalized.
- specifications of collection box
- placement
- management
- methods of collection
old lamps must be collected by licensed trucks with roof covered to prevent leaks of falling
during the transportation with facilities to absorb shocks to prevent breakage
- methods of recycling and treatment
The operators must use the glass as raw material for making new glass material or glass
products and recover mercury as a metal mercury or mercury compound using the absorption units
that satisfy the government specification. .
- conditions for license
Anyone who plans to operate fluorescent lamps recycling or other treatment facilities must
have licenses from the government before he starts the operation work.
* specifications for recycling facilities
sites
units
other auxiliary facilities
to be completed by unit manufacturers
6.2 Preparing basis for commercial business
In order to facilitate commercial operation of the facility and induce participation of private
funds government must show the profitability of the facility operation in the first phase. Government
must ensure the qualifications of operators in selecting the first operator of the facility for the stable
operation without any technical or operational problems encountered. Government must also ensure
enough revenue to finance the operational cost and depreciation cost. Depreciation cost may be
accumulated in a separate account for the future construction programs. For this purpose government

must conduct cost analysis and to estimate future operation cost. Most of all there must be strong
measures to enforce manufactures to recycle their defected goods by making contract with the facility
operators.

Appendices
1. summary of survey
to be completed
2. Rules and standards for collection and transportation and specifications of collection
box
will be provided by unit suppliers.

3. cost estimation
to be revised after all price data are collected
collection, transportation, processing
Cost items
Unit Cost
References
Korea Egypt
Collection
costs
Collection
cost
Labor costs
172
0.688
Depreciation costs
(vehicles)
8
0.032
Vehicle maintenance
costs
17
0.068
Subtotal
197
0.788
Storage
and cargo-
handling
costs
Labor costs
104
0.416
Depreciation costs
(instruments)
-
Maintenance and repair
costs (instruments)
-
Land costs
4
0.016
General operation costs
(labor costs)
-
(others)
15
0.060
Subtotal
123
0.492
Transport costs
Labor costs
46
0.184
Depreciation costs
(vehicles)
6
0.024
Vehicle maintenance
costs
11
0.044
Subtotal
63
0.252
Operation cost
Cost items Unit Cost References

Korea Egypt
Processing costs
Labor costs
24
0.096
Deprecation costs
(instruments)
60
0.240
0.240
costs (instruments)
19
0.076
0.076
Waste processing costs
13
0.052
0.052
Material and other costs
23
0.092
0.092
Land costs
3
0.012
-
(labor)
22
0.088
(instruments)
6
0.024
0.024
(others)
80.032 0.032
Subtotal
177
0.708

Cost items
Unit Cost
References
Korea Egypt
Processing costs
Labor costs 0.096
Deprecation costs
(instruments)
2.400 2.400
costs (instruments)
0.076 0.076
Waste processing costs 0.052 0.052
Material and other costs 0.092 0.092
Land costs 0.012 -
(labor)
0.088
(instruments)
0.024 0.024
(others)
0.032 0.032
Subtotal 0.708
price of new FL
4. comparison of acts and laws revision
to be completed after all the material are collected
Name/clause current revision
Prime Minister's Decree No.
338 of 1995
defected flourescent lamps are
not included as hazardous
waste
dfl classified by hazardpous
industrial waste

Refenence: related clauses
Law 4
Chapter II
Hazardous Substances and Waste
(Flourescent lamp producers)
Article (25)
It is forbidden to displace and use hazardous substances and waste without a license from the
competent authority indicated for each as hereinbelow:
2. Hazardous industrial substances and waste - Ministry of Industry.
7. In respect of other hazardous substances and waste, the respective bodies competent to
issue a license for their displacement shall be designated by a decree of the Minister for
Environmental Affairs on the basis of a proposal by the CEO of the EEAS
(recyclign facility operator)
Article (26)
Procedures for granting a license:
Conditions for granting a license:
Article (27)
- for a maximum period of five years subject to renewal.
- The licensing authority may revoke the license or suspend the activity
Article (28)
The management of hazardous wastes shall be subject to the following rules and procedures:
1- Engendering Hazardous Waste:
A-Try hard to reduce the rate at which such waste is produced,
B-Categorize the waste produced, in terms of both quantity and quality, and register same.
C-Establish/operate units to treat waste at source, with the EEAA approves.
collect and transport it to the disposal sites determined by the local authorities and the competent
administrative and environmental bodies.
2-Stage of Collecting and Storing Hazardous Waste:
A- locations for the storage
B- Store hazardous waste in special containers made of a solid, non-porous, leak-
proof material.
C- Place a clear sign
D- Lay down a schedule for the collection
3-Stage of Transporting Hazardous Waste:
5-Stage of Treatment and Disposal of Hazardous Waste:

A-sites
B-Processes reutilization
C-Processes disposal
D-limiting and reducing
E-monitor the sites of utilities and their surroundings for the treatment and disposal of
hazardous waste.
F-responsibility for damage caused to third parties
Article (29)
It is prohibited to construct any establishment for the purpose of treating hazardous waste except with
a license issued by the competent governorate after consulting the EEAA, the Ministry of Health, the
Ministry of Labour and Manpower, and the ministry concerned with the type of waste according to the
provisions of Article (25) of these Executive Regulations, after ensuring that such establishment
satisfies all the conditions which guarantee the safety of the environment and the staff employed
thereat.
The Minister of Housing, after consulting the ministries of Health and Industry and the EEAA, shall
determine the locations and conditions for the disposal of hazardous waste.
Article (33)
The owner of an establishment whose activity results in hazardous waste pursuant to the provisions of
these Executive Regulations shall be held to keep a register of such waste and the method of its
disposal, as well as of the names of the parties contracted with to receive the said waste, as follows:
1) Name and address of the establishment.
2) Name and job title of the person responsible for filling in the register.
3) The period covered by the current data.
4) The special conditions issued for the establishment by the EEAA.
5) A list of the types and quantities of hazardous waste resulting from the establishment
activity.
6) Method of disposal thereof.
7) The parties contracted with to receive the hazardous waste.
8) Date on which the form is filled.
9) Signature of the officer in charge.
Article (57)
No building permit shall be granted for the construction of any establishments or public places on or
near the seashore which would result in the discharge of polluting substances in violation of the
provisions of the Law, of these Executive Regulations and of the decrees issued in implementation
thereof unless the provisions of Chapter I of Part One of these Executive Regulations relating to
development and the environment are duly observed. The permit holder shall provide suitable and
adequate units for the treatment of waste which he shall begin operating promptly when the

establishment commences operations. He is held to secure the safety and maintenance of these units
on a regular basis.
2) Executive Regulation of LAW NMBER 4 of 1994 EGYPT prime minister’s decree No. 338 of
1995
Chapter IV Incentives (for the inducement of private funds)
Article (9)
Within six months from the date these Executive Regulations come into force, the EEAA shall, in
collaboration with the Ministry of Finance, lay down a system of incentives which the EEAA and
competent administrative bodies may offer to agencies, establishments, individuals and others who
undertake activities or projects that protect the environment, provided due consideration is given when
laying down such system to the privileges and conditions prescribed in laws and decrees, particularly
to those related to investments, customs, industry, cooperatives and others.

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