Commentary on “General Technical Guidelines for Environmentally Sound Management (ESM) of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants (POPs)”

UK comments on the 1st draft

General Structure and Purpose

  1. Overall this is a welcome start to a complex topic. In order to assist the Parties and the producers of the document some of the objectives need to be teased out and delineated. The following comments are therefore more addressed to better defining the structure and purpose of the paper rather than a detailed critique of the content. Most of the latter is useful and can be enhanced with clear delineation and presentation of the topics.
  1. We had understood that the structure of the POPs guidelines would have this overarching document. In order to be a true guideline this should concentrate on providing some more practical and definitive information.
  1. The guidance document seeks to achieve a number of aims according to the introductory paragraph 1.1 “Purpose” namely:

(1)a stand-alone general guidance resource, and

(2)a guide for the preparation of technical guidance documents on specific POPs wastes

  1. For 1) it will also discuss “associated policy issues” and for 2) the document “eliminates the need to address the generally applicable provisions of the conventions and associated policy issues in each specific technical guidance document”.
  1. While these are good aims they are addressed to implicitly different readerships. The first type might be those seeking to carry out the task (of destroying POPs) or prepare national approaches to do so, the second being those writing the other guidelines. A third group is the POPS Working Group itself that may wish to initiate action to try and resolve some of the issues identified. There is a risk that significant parts of the document will be of much less interest to any particular reader and hence lose impact.
  1. Achievement of the second aim will be especially helpful during the formulation of the POPs guidelines. In particular this might be seen as time-limited; once the other guidelines have been completed such sections will be only of historical interest.
  1. But much of this and the policy issues discussed in the other sections are secondary to actual provision of guidance itself, which should be as clear, authoritative and unambiguous as it can be.
  1. It therefore seems preferable to concentrate on arranging this Guideline into three sections:

i)General guidelines containing an overview of the purpose and scope of each of the Conventions; the definitions of POPS and Wastes, descriptions of sampling methodologies and treatment processes and essential references for resource materials websites etc (with its own appendices)

ii)A discussion section on the “issues” raised eg determination of the meaning of “trace”

iii)A “guidance on guidance” section identifying the common structure and topics to be addressed in detail in each of the suite of documents that comprise this series.

  1. The first section should be one that remains as a complement to the other guidelines and can be read in a free-standing way for those with no need for the other parts. The others are precursors to their completion.

Presentation of Issues for debate to POPs Working Group

  1. We would prefer to see the issues described and other paragraphs debating relevant matters in a report to the OEWG’s POPS working group and the Parties rather than in the body of a document. This can then be used to enable the Basel OEWG and Stockholm groups to take decisions on the aspects that need to be resolved. In any event the structure described above should be considered for adoption to give clarity to the different elements.

Examples of different elements of the Guidelines

Introduction

  1. It is over ambitious to suggest to “eliminate” reference to the provisions of the Conventions. Each guidance document will need (should not try and escape) a short introductory paragraph that outlines its context. Better to construct that paragraph for replication. Otherwise all readers will always require at least two documents – the General Guidelines (itself containing out of date information or discussion on issues that will have later been resolved) and the specific one for the POP of concern.

Issues

  1. Chapter 3.0 “Implementing convention provisions”. Section 3.1.1 on establishing the meaning of “trace” – is an example of an issue for resolution. Hence 3.2 et seq. become sections of debate rather than a practical matter of guidance. They are relevant matters but for a different audience eg. that needs to take decisions on standards or develop some techniques.

Technical guidance

  1. Section 5.7 is a good example of content for the overall technical guideline. Unfortunately it is only a short paragraph. This could usefully be expanded to give more references on relevant analytical protocols and sampling techniques. The authors may have in mind a model approach that can be used for a variety of POPs.

Guidance on Guidance

  1. Chapter 6 is a good start to the development of the common structure for this suite of guidelines.

General

  1. We should try to avoid mixing topics within sections for example Section 3.5is “Guidance on establishing levels of destruction”. It also includes discussion on destruction technologies. This should be a separately headed section cross-referenced to the descriptions given in the appendix.