Flying in the face of the long-standing KwaZulu Natal medical waste incineration ban issued by the provincial Department of Health after the last incinerator in KZN failed, the national Department of Environmental Affairs has just issued a waste management licence to a company called Sirela Trading for its proposal to build and operate a medical waste incinerator in Mkondeni, Pietermaritzburg.

Sirela Trading has no previous experience in the field of medical waste incineration and is proposing to buy and construct a facility from a local engineering firm.

Incineration is the least desirable technology to treat and dispose of medical waste and has a long history globally and in South Africa of poor operation and maintenance, massive pollution episodes, technology failure, illegal dumping and environmental prosecution by the Green Scorpions. Most recently, a medical waste incinerator operated by EnviroServe in Bloemfontein has been adversely affecting neighbouring residents over the past few years failed spectacularly when it burnt its smokestacks causing a massive smoke plume in the process.

In 2009, the Green Scorpions unearthed 300 tonnes of untreated medical waste buried within a brickworks, 20 tonnes of medical waste buried in an unused Harmony Gold mine shaft, and a further two illegal dumps, one on a game farm 20km outside Welkom and the other at the town’s show-grounds. The owner of the brickworks where the initial 300 tonne dump was discovered was also one of Wasteman’s contracted transporter of medical waste arising from hospitals in Durban to the Wasteman's incinerator in Klerksdorp.

The dumped medical waste comprised anatomical waste (amputated legs, arms, placentas and foetuses), pharmaceutical components, and general medical waste including used syringes, contaminated gloves and blood-stained material.

Ideally there is no need for medical waste incinerators to exist at all in South Africa were it not for an entirely unnecessary requirement by the National DEA in the draft Health Care Risk Waste Regulations currently disputed by the National Department of Health. Typically medical waste comprises general waste, health care risk and anatomical waste, and hazardous waste. Each waste stream is equally problematic and potentially poses a health risk.

However, research shows that more than three quarters of what health care facilities discard is similar to what we throw away at home. As with our household waste at home, much of the waste is paper and packaging and most of it never comes into contact with patients. In fact, infectious waste – that which we really need to be careful about treating is even less than the remaining 15% of the medical waste stream – typically 5%, and all of it can be disposed of safely by proven disinfection methods other than incineration which is fast becoming the global norm.

The DEA currently “rigidly” requires elements of health care risk waste to be incinerated and herein lies the root of the medical waste crisis. Health care risk waste is defined by them as: “…waste capable of producing any disease and includes but is not limited to the following: laboratory waste; pathological waste; isolation waste; genotoxic waste; infectious liquids and waste; sharps waste; chemical waste; and pharmaceutical waste.”

From this definition the DEA requires that pathological and anatomical waste can only be incinerated and for this reason provinces that do not have incineration capacity have to transport this waste to incinerators in other provinces. This is despite there being alternative technologies, such as the autoclaves, that they currently use to treat the general medical waste, and which meet the required international standard of sterilisation for health care risk waste. This construct further necessitates that the private sector in various provinces to have sub-contracts in order to treat their waste requiring incineration and it is in this manner in that complex web of contracts and subcontracts are spun and is how waste eventually ends up in a ditch located in a brick factory. 

In South Africa, health care risk waste that requires special treatment and disinfection is placed into red bags at source. Nevertheless, health care facilities that use private waste contractors do not have in place separation at source, recycling, reuse and composting policies and routinely misplace large amounts of their general health care waste (including recyclables) into red “health care risk waste” bags which most private waste contractors are happy to burn in incinerators, (including the recyclables) because the more red bag health care risk waste they process in their contracts the bigger the profit.

However, of the 42, 000 estimated tonnes of health care risk waste arising in South Africa per annum the percentage of this fraction that is defined as “pathological and anatomical waste” is estimated at approximately only 5% (2100 tonnes per annum). If it were only this proportion of the waste stream that required incineration then one could safely assume we have an “over capacity” of health care waste risk incineration in South Africa and that medical waste does not, in fact, require incineration which is needlessly been being transported, stockpiled and incinerated at a current risk to the public’s health (considering the poor regulatory and compliance record of the health incineration industry).

Furthermore, most current health care risk waste incinerators in South Africa will not meet the provisions of the pending “listed activities and associated minimum emission standards” identified in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) and will in fact be shut down if the DEA applies these standards.

We consider a logical approach for the KZN DoH and DEA to follow would be to legislate and encourage the phase-in of alternative technologies to treat health care risk waste.
- Rico Euripidou

Rico Euripidiou is the Environmental Health Campaigner at groundWork, Friends of the Earth South Africa.