Assessing the constraints to recycling mill scale in a South African iron and steel industry

Abstract : The National Environmental Management: Waste Act (NEMWA) (Act No. 59 of 2008) of South Africa regulates waste management in the country. NEMWA (Act No. 59 of 2008) focuses on the goal of zero waste to landfill, however, only 10% of the total waste generated annually is recycled (DEA, 2011). South African industries contribute to a significant percentage of the total waste volume, yet recycles only 4% of its waste (GDACE, 2007). The South African Iron and Steel industry generates high volumes of unique wastes such as mill scale which, although hazardous in nature (Zhang et al., 2016), has a high re-use potential. However, the Gauteng province alone has a backlog of 15000 tons of mill scale (GDACE, 2007). The aim of this study is to assess the constraints to recycling mill scale generated by the Iron and Steel industry in South Africa. This research begins with a case study which investigates the generation of mill scale at ABC Metals, an Iron and Steel industry in Gauteng. The composition of mill scale, volumes generated and its potential use in an alternative process provide an understanding of its recycling value. Secondly, a review of global waste legislation demonstrates how different regions regulate waste and waste recycling; the effect that waste legislation has on waste recycling in an industry and specifically how legislation influences the recycling of mill scale in South Africa. Lastly, the extent to which industry needs and practicalities are incorporated into the drafting of waste management strategies and waste legislation by the Department of Environmental Affairs (DEA) (the South African custodian of the environment and legislating authority) is evaluated by reviewing the outcomes of the quarterly DEA-Industry Waste Management Forums (DEA-IWMF) which are documented in the minutes of the meetings. While alternative uses exist for mill scale, South Africa’s waste legislation has a strong focus on a controlling-type regulation which obstructs opportunities to recycle industrial waste streams, mainly due to the time and monetary constraints associated with obtaining a requisite recycling licence (Park, 2014). An industry seeking to use a waste stream in its process does not identify itself as a waste manager or waste service provider since its primary function is manufacturing. For this reason, the industry is reluctant to apply for a Waste Management Licence and may retreat to using raw materials in order to remain legally compliant. Drafting and promulgation of waste legislation should thus take into account the experience and needs of industries. A regular forum between the legislator and industrial stakeholders is an important channel for ensuring that waste management in an industry is sustainable and practical. Such forums should provide a correlation between the operational environment of industries and the lawmakers (Levänen, 2014a). However, analysis of the DEA-IWMF minutes indicates that the legislator does not adequately consider industries’ concerns on waste legal matters or provide sufficient feedback on waste management compliance issues.M.Sc. (Environmental Management