TL: THE FAILURE OF THE EC TO IMPLEMENT ITS WASTE MANAGEMENT STRATEGY SO: Greenpeace International, EC Unit (GP) DT: May 14, 1992 Keywords: toxics ec europe policy waste disposal legislation failures greenpeace reports gp / "Critique of the Proposal for a Council Directive on the Incineration of Hazardous Waste and the Fourth and Final Draft of the Proposal for a Directive on Packaging and Packaging Waste." Prepared by Lisa Finaldi, Incineration Coordinator Anita Fokkema, EC Toxic Lobbyist SUMMARY EC PROMOTES WASTE INCINERATION, NOT ITS PREVENTION FIRST POLICY Since 1989, the European Community has reiterated that prevention is its waste management priority. Recycling and reuse are secondary and disposal a final option in the policy hierarchy. Unfortunately, close examination of policy implementation since then shows that the Community has turned its priorities upside down. Waste incineration is currently the EC's favourite waste management option. This is most evident in the proposals on hazardous waste incineration and on packaging waste. Both proposals legitimise and promote incineration as if it did not pose serious risks to human health and the environment. Moneywise, the Community also puts more funding into the construction of incineration plants and the development of disposal techniques than into clean production alternatives. Directives establishing targets for hazardous waste prevention and reduction are lacking completely. Initiatives which would contribute to this, such as eco-auditing and priority waste stream projects, are dependent on the voluntary action of waste producers. Useful legislation on waste liability has simply disappeared from the EC agenda. Greenpeace therefore demands the immediate implementation of the adopted Waste Managment Policy by: 1. Amending the proposed directive on hazardous waste incineration to include a moratorium on the expansion of hazardous waste incineration capacity and to exclude chlorinated waste from incineration. Chlorinated waste is one of the major sources of dioxin emissions by incinerators, which according to new medical and scientific evidence pose significantly higher risk to human health than previously assumed. 2. Withdrawal of the fourth draft proposal on packaging and packaging waste, and the presentation of a serious proposal that includes waste prevention targets and a phase out of chlorinated packaging, as well as significant targets for real recycling - not for disposal in disguise. 3. Mandatory environmental auditing for industries using toxic substances or generating hazardous waste, so that detailed data on hazardous waste production become available, and the implementation of alternative clean production methods is actively promoted at the plant level. 4. The introduction into the Fifth Action Programme of a plan of legislative measures to reduce and phase out the use of hazardous substances which are persistent, bio-accumulative and toxic, beginning with chlorinated substances. 5. Redirection of Structural Fund, R&D and LIFE financing from waste disposal to waste prevention options. 6. Adoption of the modified proposal for a directive on the liability for damages caused by waste. These measures will constitute the first critical step towards preventing and reducing the Community's mountains of hazardous waste. They would put prevention at the centre of Community policy, in place of disposal options which should only be considered as a last resort. The EC would thereby be safeguarding the health of present and future generations, and dealing with the current waste crisis at source - as precaution requires. TABLE OF CONTENTS Page SUMMARY - EC Promotes Waste Incineration, not its Prevention First Policy 1 Chapter 1: EC Waste Management Strategy 2 1.1 Overview of Policy Intent 2 1.2 Implementation 3 Chapter 2: Hazardous Waste Incineration Proposal (COM (92) 9 FINAL) 4 2.1 Alarming New Medical Evidence about Dioxin 4 2.2 Failure of Incineration Proposal to Regulate Dioxin Emissions 5 2.3 Need for a Precautionary Approach 6 2.4 Greenpeace Demands A Ban on the Incineration of Chlorinated Wastes 6 2.5 Complete Waste Destruction is Impossible 7 2.6 Current Emission Limits Are Not Being Met 7 2.7 Greenpeace Demands Moratorium on New Incineration Capacity 8 Chapter 3: Packaging and Packaging Waste Proposal (DGXI-A4/Draft #4) 9 3.1 Commission Draft Proposals and Industry Pressure 9 3.2 No Quantitative or Qualitative Prevention or Reduction 10 3.3 Incineration Cannot Be Equivalent to Recycling 10 3.4 Greenpeace Demands Withdrawal of Proposal 11 Chapter 4: EC Waste Prevention Programmes 12 4.1 EC Funds of Clean Technology 12 4.2 Greenpeace Calls for Clean Production 12 4.3 Priority Waste Stream Projects 13 4.4 Shortcomings of the Chlorinated Solvent Project 13 Appendices Dioxins and Furans in Breastmilk Fat - Levels Found in Various Countries. Nederland Brandschoon? Waste Incineration: Too Expensive and Not Without Risks; Statement of the Dutch Association of Medical Ecologists. CHAPTER 1 EC WASTE MANAGEMENT STRATEGY THE IMPLEMENTATION OF EC WASTE MANAGEMENT STRATEGY FAILS IN ITS PRIORITY OBJECTIVE OF WASTE PREVENTION The problems associated with the proposed Directives on hazardous waste incineration and packaging and packaging waste need to be considered within the general context of EC waste strategy implementation. The failure of the Community to translate its reiterated priority objective of waste prevention into concrete measures and/or legislation is becoming increasingly apparent. In real and legislative terms, the regulation and even promotion of disposal options as solutions to the hazardous waste crisis is now the main focus of Community activity. 1.1 OVERVIEW OF POLICY INTENT In 1989 the Community Strategy for Waste Management to the year 2000 defined a hierarchy of waste management options. Priority was given to waste prevention, followed by the promotion of recycling and reuse, and then by the optimisation of disposal methods. The European Parliament, in the Bowe report on this Community strategy, underlined that "clear targets for both waste reduction and for levels of recycling and reuse should be set and specific action taken both at the EC level and by the individual Member States." It further proposed that the Commission compile and maintain high quality data on the quantities and characteristics of agricultural, industrial and domestic wastes (...) "so that meaningful reduction targets may be established." With respect to waste prevention, the Parliament also considered that "it must be possible to ban products that have highly damaging effects at the disposal stage." In 1990 the Council of Ministers endorsed the Community strategy, stating that "where the production of waste is unavoidable, recycling and reuse of waste should be encouraged provided that such recycling or reuse is carried out in environmentally acceptable conditions." In 1991, the Maastricht Treaty on European Union introduced precautionary action as a guiding principle for EC environmental policy, thereby reinforcing the importance already given to prevention. The recently published Fifth Action Programme on the Environment and Sustainable Development reiterates and proposes to reinforce the 1989 Strategy, while noting that hazardous waste requires particular attention. 1.2 IMPLEMENTATION It appears, however that prevention priorities are being lobbied away, while "end-of-pipe" regulations are becoming the main focus of EC legislative activity. The net result today is that the waste management hierarchy has been turned upside down. The recently amended framework directive on waste still accords priority to the prevention or reduction of waste production, while quoting as secondary options "the recovery of waste by means of recycling, re-use or reclamation or any other process with a view to extracting secondary materials" or "the use of waste as a source of energy." At the same time, however, this article places "the use of waste as a source of energy" on an equal footing with re-use and recycling. It thereby creates a loophole which allows the EC to promote incineration with energy recovery as an equivalent to recycling and re-use. This represents a major setback to the Community's professed objectives. Nor do recent developments in other waste related legislative proposals provide much hope for waste prevention: * Draft proposals for reductions in packaging waste have been bombarded with criticism by industry as a whole and UK packaging industry interests (INCPEN) in particular. As a result, concrete targets for the prevention and reduction of the amount of packaging waste produced have been abandoned; * The Commission's amended proposal for a directive on liability for damage caused by waste, which would have made a significant contribution to strengthening the Community's stated waste management objectives, has simply been taken off the Council agenda, due to stiff opposition from industry and insurance companies; * The proposed regulation on environmental auditing does not require industries to be accountable for good environmental housekeeping, to account for the hazardous waste they produce, or to take appropriate measures to prevent or reduce such waste; * The incineration and landfilling proposals do not set any limits to the expansion of disposal capacity, and therefore provide no incentive for waste prevention. On the contrary, they appear set to perpetuate and promote incineration and landfilling as acceptable solutions to the current waste crisis; The reversal of EC waste management priorities is also made clear in the upcoming proposal on packaging and packaging waste and hazardous waste incineration, the Priority Waste Stream Project on Chlorinated Solvents, and EC funding of the development and application of clean technologies. CHAPTER 2 HAZARDOUS WASTE INCINERATION PROPOSAL (COM (92) 9 FINAL) The proposal for a directive on the incineration of hazardous waste fails to address serious new medical evidence regarding the health effects caused by exposure to dioxins. In addition, the proposal calls for 100% destruction of hazardous waste during incineration - a requirement that is impossible to meet. This chapter examines new dioxin information as well as the reality of incineration performance and makes recommendations for improvements to EC waste management policy. 2.1 ALARMING NEW MEDICAL EVIDENCE ABOUT DIOXIN Polychlorinated dibenzo-p-dioxins and dibenzofurans, called dioxins and furans, are only one group of halogenated products of incomplete combustion that are emitted by hazardous waste incinerators which burn chemicals such as chlorine, bromine, fluorine or iodine. This group of chemicals, which is now ubiquitous in the environment, has been the subject of intense scientific scrutiny due to widespread recognition that these substances are extraordinarily toxic, persistent and bioaccumulative. Since the formulation of the proposed directive, striking new evidence about the potential human long-term health effects of dioxin has been gathered. New research confirms that dioxin is not only a powerful carcinogen but can also cause immunological, developmental and neurological effects. Dioxin is now known to trigger abnormal cell processes, resulting in a variety of cancers. One recent study that examined the health records of 5,000 exposed workers at a dozen chemical plants demonstrated that these workers were more likely to die from cancer than members of the general population. A second study of 1,500 pesticide plant workers in Germany showed that dioxin-exposed workers exhibited a significantly higher mortality from all cancers than members of the general public. The mortality of workers with more than 20 years of exposure from these causes was 87% above normal. These and similar studies have led researchers to investigate how dioxin exposure at much lower levels could affect human health using more subtle indicators than cancer. To date, in animal studies, minuscule levels of dioxin have been shown to suppress the immune system of mice, giving rise to concerns about the human body's ability to defend against disease. Similarly the body's hormonal system may be affected since dioxin boosts the potency of some hormones while suppressing the effects of others. Male chemical workers chronically exposed to dioxin, for example, showed reduced levels of the male hormone testosterone. Some studies of rats have shown delayed sexual development, significantly reduced sperm count, and feminization of sexual behaviour in males exposed to dioxin while in the womb. Other studies have turned up evidence that furans can impair brain development in unborn children. One study has found that children who had been exposed to significant doses of furans while in the womb suffered from lower IQs, increased hyperactivity and delayed development of normal coordination, perception and memory. The US Environmental Protection Agency (EPA), in an announcement on 28 April 1992, stated unequivocally that recent scientific results show that dioxin not only causes cancer in humans, but also immunotoxicity and reproductive effects, which occur at body burdens approximately 100 times lower than those associated with cancer. The EPA also concluded from recent data that there may not be a threshold for certain responses to dioxin and that human sensitivity to dioxin is similar to that of experimental animals - not less, as had been previously supposed by some researchers. Even more important, EPA admitted that some subpopulations are at higher risk than others: these include nursing infants exposed to contaminated breastmilk, and recreational and subsistence fishers who consume their catches. 2.2 FAILURE OF THE INCINERATION PROPOSAL TO REGULATE DIOXIN EMISSIONS Although there is increased evidence of the harmfulness of dioxins and furans, the European Commission proposal simply admits that it is impossible to control dioxin and furan emissions. There is, in the words of the authors of the proposal, "no reliable method to ensure the respect of a legally binding limit-value" for such emissions. Article 9.2 of the proposal merely establishes a "guide value" for dioxin emissions requiring that dioxins and furans "be minimized by the most progressive techniques." But this guide value is in fact unenforceable. Moreover, reliable measurement techniques are not available, thus dioxin emissions are not subject to any real control at all! It is significant that the European Commission's proposal admits its inability to measure or control a group substances that constitute a severe risk to human health and the environment, associated with hazardous waste incineration. It manages no more than a weak statement that incinerator operators should try their best to address the problem. Greenpeace, in common with concerned citizens living near incinerators, and workers in incineration facilities, lacks confidence in the EC's measures. However, despite the fact that EC Directives 80/1107/EEC and 89/391/EEC are cited in the proposal, no special measures are foreseen within the draft directive to protect the health of incineration plant employees. 2.3 NEED FOR A PRECAUTIONARY APPROACH The latest medical evidence concerning dioxin clearly indicates that a precautionary approach is critical, given the wide range of effects these substances can have on human health. Every possible precaution should therefore be taken to avoid the generation of dioxins and environmental contamination by them, especially over the long-term, where human reproduction and intellectual potential may be affected. The precautionary approach was clearly sounded in the 1990 London Dumping Convention, which banned the incineration of toxic waste at sea due to its potentially detrimental effects on the marine environment. Chlorinated compounds were the main feedstock for ocean incineration, because of the problems that had been experienced at land-based incinerators. The current approach thus does no more than revert back to the previously failed strategy. The International Joint Commission on the Great Lakes in the USA and Canada recently called for a precautionary approach, recommending that "incineration facilities in the region be phased out of use or required to eliminate the production and emissions of dioxins, furans, PCBs and inorganic material, especially mercury and hydrochloric acid." This action was proposed because incineration is considered to be the most rapidly growing source of dioxins and mercury in the Great Lakes. 2.4 GREENPEACE DEMANDS A BAN ON THE INCINERATION OF CHLORINATED WASTES The European Community has embraced the precautionary principle in the Maastricht Treaty. If environmental policy is to be consistent with the Treaty, it is incumbent upon DG XI to implement the precautionary approach in all its directives, and specifically in the proposed directive on the incineration of hazardous waste. For Greenpeace, emissions of dioxin must and can be significantly reduced within the framework of the proposed directive through the exclusion from incineration of chlorinated substances, chlorinated solvents, and chlorinated plastics such as PVC, PCBs, and CFCs, which comprise major sources of dioxin when burned. By following such an approach, the EC would be joining an important trend in environmental policy making. 2.5 COMPLETE WASTE DESTRUCTION IS IMPOSSIBLE Article 3.5 of the proposed directive requires that hazardous waste burning achieve complete destruction - in other words 100% destruction and removal efficiency (DRE). This standard unfortunately cannot be met. DRE is directly related to the emissions of an incinerator. In other words, inefficient combustion will lead to more emissions. In fact, officials from the US EPA and private research scientists in the US now admit that hazardous waste incinerators emit hundreds of times more dioxins and other toxic pollutants than allowed by US EPA regulations. In March 1992, US EPA scientists admitted that modern hazardous waste incinerators simply cannot comply with federal regulations because they cannot destroy all chemicals to a destruction and removal efficiency of 99.99%. Furthermore, certain toxic wastes such as dioxins and PCBs are supposed to be burned at an even higher DRE, 99.9999%, but EPA scientists are now admitting that they have recognized since 1985 that hazardous waste incinerators cannot meet these requirements. This information has only recently come to light as part of an independent Greenpeace evaluation of dioxin emissions from an incinerator in Jacksonville, Arkansas where 7,484 metric tonnes (16.5 million pounds) of herbicides (2,4,5-T and 2,4-D) left over from the Vietnam War are now being incinerated. Government officials confirmed Greenpeace's findings that the Jacksonville incinerator was only achieving 99.96% DRE of dioxins. Two government reports provided further verification. Tests conducted in 1984-1985 by US EPA consultants showed that incinerators cannot be expected to achieve 99.9999% DRE for any chemical in waste that occurs in concentrations lower than 10,000 parts per million: i.e. dioxins and PCB-contaminated soils. Moreover, of eight major hazardous waste incinerators studied, none could achieve 99.99% DRE. In a March 1992 interview, the author of that study categorically stated that incinerators cannot achieve the DRE required by US federal law. 2.6 CURRENT EMISSION LIMITS ARE NOT BEING MET The Netherlands and the Federal Republic of Germany have some of the most stringent environmental regulations for incineration in Europe. The proposed EC directive would go beyond the standards set in the Dutch legislation of 1989, as well as the 1990 German law on incineration. Evidence from Holland shows that incinerators are not complying with legal norms, and are important sources of serious contamination, despite attempts to control pollution. * AVR Incinerator in the Netherlands The AVR incineration complex in Rotterdam burns both municipal and hazardous waste. It is the largest incineration facility in Europe, with the capacity to burn 1.14 million tonnes of waste each year. In 1993 the dioxin limit for incinerators in Holland will be 0.1 ng TEQ/cubic metre. AVR is known to be the largest single source of dioxin emissions in Holland. In 1989, the Dutch government released a report showing high levels of dioxin in milk and meat products from 16 farms around the incinerator complex. The poisoned milk is still being purchased by the government, with the fat being separated and burned at AVR. While the government insists that this contamination is caused by the municipal incinerator alone, it is impossible to verify this assertion. AVR is currently undergoing an upgrading of pollution control equipment in an attempt to reach the required 0.1 ng TEQ/cubic metres for dioxin. With current levels at 53 ng TEQ/cubic metres, it is hard to imagine that the DFL 400 million ($ 226 million US) going into pollution control can bring the levels down to the required standard. 2.7 GREENPEACE DEMANDS MORATORIUM ON NEW INCINERATION CAPACITY The proposed incineration directive will merely serve to promote incineration and perpetuate the current toxic waste crisis. Toxic waste will only be reduced if cheap disposal options are closed off and generators are held liable for waste. In order to implement its policy of prevention first, the EC must set the stage for waste prevention through: * amending the eco-audit proposal to require mandatory auditing for industries that use or generate toxic substances as the first step towards developing clean production. This audit must then be followed by a mandatory toxic-use reduction plan with clear goals and timelines. All auditing information must be open for public inspection; * amending the incineration proposal to establish a moratorium on the increase of hazardous waste incineration capacity and a ban on the incineration of chlorinated substances; * immediately reintroducing the modified proposal for a directive on liability for damages caused by waste. CHAPTER 3 PACKAGING AND PACKAGING WASTE PROPOSAL (DGXI-A4/Draft #4) The clearest example of the "upside down" implementation of the EC Waste Management Policy is to be found in the fourth -and final - draft proposal for a Council Directive on packaging and packaging waste. 3.1 COMMISSION DRAFT PROPOSALS AND INDUSTRY PRESSURE During the drafting process of this proposal, any language which referred to concrete targets for the prevention and reduction of packaging and packaging waste, to mandatory recycling or to significant recycling targets has fallen victim to the Commission's consultations with industry. The original purpose of the proposal was to reduce the 50.5 million tonnes of packaging waste produced in the European Community each year, and to increase recycling, which is currently less than 10%. But in the final draft, even the freeze on per capita output of packaging waste at 150kg (included in the second draft) has been lobbied away by industry, with the argument that it would be a hindrance to economic growth. No concrete quantitative measure to prevent the increase of or reduce packaging waste mountains has survived. A target of 90% so called "recovery" of total packaging waste output by the year 2005, of which only 60% should be recycled, is all that remains. This leaves ample options for continued disposal by incineration in plants which recover some energy from the burning process. The final proposal almost literally copies industry's most defensive position. To quote the Common Position of Trade and Industry on the second draft: "The industry is prepared to accept an EC-wide, measurable and feasible target for the reduction of packaging waste disposed of in landfill and/or by incineration without energy recovery, provided that industry has the freedom to choose among available means including incineration with energy recovery." Qualitative prevention measures to minimize the presence of noxious heavy metals and other hazardous substances, in particular chlorinated substances, in packaging waste have also been eliminated during the drafting process. Neither limitations on the use of chlorine-bleached packaging materials, nor the transition from chlorinated/organic solvents to water based solvents in inks, varnishes and adhesives for packaging, nor the replacement of materials that pose reuse or recovery problems are to be found in the proposal. As a result, the final Commission proposal only pays lip service to preventing the use of hazardous packaging material, requiring in Annex II that "the presence of hazardous substances is limited to such a level as to minimize their presence in emissions, ash or leachate" for incineration or landfill. Here again we find the Commission caving in completely to industry demands that there be "no discrimination against any packaging type or packaging material." 3.2 NO QUANTITATIVE OR QUALITATIVE PREVENTION OR REDUCTION The absence of any objective to reduce or limit the amount of packaging and packaging waste produced in the Community makes this proposal a prime example of regressive environmental legislation. In its current form the proposed directive allows for and legitimises increases in the production of packaging and packaging waste. With regard to recycling and reuse, the proposed target of 60% by the year 2005 is hardly more than a confirmation of existing situations and trends. The most disturbing feature of the proposed directive, however, is the total absence of any prevention or reduction goals in the use of hazardous chemicals in packaging material and the generation of hazardous packaging waste. Prevention through the reduction and phase-out of hazardous packaging must be a major objective according to established waste management policy principles. In all cases, one priority must be set: PVC and other chlorinated packaging must be targeted for phase-out. PVC additives in packaging leach into food and drink and may pose a direct risk to the health of consumers. For this reason, member states such as Greece and Italy forbid PVC use in drink containers or require that it be mentioned on the container. In addition, PVC and other chlorinated substances create highly dangerous dioxins when incinerated. Valid recycling options for PVC are extremely limited due to the various additives in PVC which make recycling nearly impossible. 3.3 INCINERATION CANNOT BE EQUIVALENT TO RECYCLING A third major shortcoming of the proposal is the way it places refilling, recycling and incineration on an equal footing, as equally valid methods for reducing the environmental impact of packaging waste. Reintroducing disposal methods such as incineration through the back door of energy recovery empties the apparently impressive target set for recovery of any significance. The marking system of packaging proposed in the draft would simply mislead consumers, by putting an identical symbol on packaging to be incinerated in a plant with energy recovery as on recyclable packaging. If any attempt is to be made to comply with the Commission's own hierarchy of waste management goals, reutilisation of packaging should be given precedence over recycling. Incineration with or without energy recovery should be judged for what it is: an unsafe disposal method. 3.4 GREENPEACE DEMANDS WITHDRAWAL OF PROPOSAL The final draft of the proposal for a directive on packaging and packaging waste, if adopted, would result in the production of more packaging waste every year. This in turn would result in an increase of packaging waste incineration, and resultant dioxin and heavy metal contamination. Industry is being given a mandate to increase the amount of packaging waste and to incinerate large amounts of it, thereby making the entire exercise of proposing and adopting this directive ludicrous. In fact, the proposed directive is likely to become an obstacle to progress in reducing packaging mountains to acceptable proportions. The mere fact that this directive is in preparation has led some Member States to postpone sensible measures they were planning to reduce packaging waste. The Republic of Ireland, for example, has put on hold its measures to prohibit the use of cans for alcoholic drinks in expectation of the EC Directive. The EC proposal is, in many respects, also considerably weaker than what has been voluntarily agreed between the Dutch government and a substantial part of Dutch industry in the "Verpakkings Covenant" of 6 June 1990. As a consequence, even industry representatives from the Netherlands are protesting against the lowest possible denominator approach which characterizes the European Commission's final draft proposal. Many national measures - including the Dutch case of reductions in the use of PVC and a phase-out of chlorine-bleached beverage cartons - are now under threat because the proposed directive (based on Art. 100a of the Treaty) would not allow Member States to take more stringent measures. In the final analysis, the European Commission's preoccupation with the internal market and free trade, combined with industry demands of "no discrimination" against any packaging material, are clearly in conflict with environmental and human health protection. Protection by definition implies discrimination; leaving the prevention of packaging waste to the forces of free trade will most definitely accelerate the pace of environmental destruction -be it in terms of resources or by waste. In conclusion, the proposal certainly has very little to offer from a viewpoint of environmental protection; on the contrary, it is and will increasingly be an obstacle to it. Obstructionism by industrial interests has clearly taken an unacceptable toll. Greenpeace therefore concludes that the European Community is better off without this proposed directive, and challenges the European Commission, the European Parliament and the Council of Ministers to have it withdrawn and revised in accordance with the established priorities of EC Waste Management Strategy and policy. Without such a revision, consumer boycotts will result. CHAPTER 4 EC WASTE PREVENTION PROGRAMMES While the policy priorities of prevention and reduction at source are basically absent from the legislative initiatives of the EC, they are also insufficiently reflected in EC funding programmes and in its waste stream analysis programme. 4.1 EC FUNDING OF CLEAN TECHNOLOGIES DG XII (Research and Development) is funding a 246 million ECU R&D Programme in the Field of Environment (1991- 1994), which is supposed to contribute to the technical and scientific basis for the implementation of EC environmental policy. One of the general objectives of the programme is "the promotion of cleaner technologies, defined as " new or modified processes aiming at fewer emissions, less waste and/or less consumption of raw materials and energy." The programme also envisages "the promotion of methods for treatment and safe disposal of waste" and "the investigation of suitable practices for the restoration of abandoned disposal sites and contaminated areas." The DG XI "Action by the Community on the Environment" Programme (ACE) has in past years been meant to fund research and demonstration projects in clean technologies. In the meantime, ACE has been integrated into LIFE, the new financial programmme for the environment, Council approval of which is still pending, as is the 400 million ECU to be spent on environmental protection programmes through 1995. According to the final Council document on LIFE, 40% of the proposed 400 million ECU will be spent over three years (1993-1995) on seven types of actions, one of them being "actions aimed at developing or utilising new clean technologies." Clean technologies are then defined as "creating little or no pollution and likely to save on resources." Assuming for the sake of calculation that such actions are of equal importance, this would mean that LIFE may be expected to spend about 26 million ECU over three years on clean(er) technologies, while a larger amount is likely to be spent on cleaning up polluted sites and finding better end-of-pipe solutions to waste problems. 4.2 GREENPEACE CALLS FOR CLEAN PRODUCTION It is obvious that EC funding programmes do not give appropriate emphasis to clean technologies; beyond this, the EC approach is more one of cleaner than of clean technologies. Any project that promises to produce less (hazardous) waste or less pollution appears to qualify. Although such projects could in theory make a positive contribution to preventing waste generation and reducing pollution at source, they do not necessarily do anything of the kind. Particularly in the case of those materials which are toxic, persistent and bioaccumulative, the only acceptable objective is not to produce them in the first place. A much stricter definition of clean technologies, if not a total commitment to funding new production methods which allow for the elimination of hazardous substances and prevent the generation of hazardous waste, is required. Technologies which eliminate the use of chlorinated substances and the generation of chlorinated waste should be made a first priority, given the grave threat the continued production, use and disposal of these materials pose to the environment and human health. Note: Structural Fund Direct Financing of Waste Disposal Plants. The low level of funding available for clean technologies, however poorly defined, is of limited importance compared to the financial assistance available to the economically weaker regions of the Community for waste disposal plants through the Community's Structural Funds, notably ENVIREG. In fact, despite the inaccessibility of data regarding project financing through these funds, there are strong indications that substantial amounts of money are being allocated for the construction of incineration plants in Spain, Portugal and Ireland. The Republic of Ireland, for example, was recently awarded 28 million ECU under the ENVIREG program, of which a significant amount is likely to be destined for the construction of a national hazardous waste incinerator. Ireland currently produces about 5000 tonnes of incinerable hazardous waste, hardly enough to make a toxic waste incinerator economically viable. Once a hazardous waste incinerator has been built, however, it will become a disincentive to waste reduction and waste prevention and a stimulus for polluting industries to move to Ireland. Greenpeace therefore demands that data be made available at the local, regional, national and EC level concerning project financing through structural funds relative to waste management; and a reform of structural funds to ensure that project financing allocations will respect established EC waste policies and give priority to the promotion of clean production methods instead of expanding waste disposal capacity. 4.3 PRIORITY WASTE STREAM PROJECTS One of the most important frameworks for waste prevention in the EC is the Priority Waste Stream Programme. The programme was set up by DG XI in 1990 and has so far dealt with at least two specific waste streams: used tires and chlorinated solvents. The purpose of the programme is to reach voluntary agreements between governments, industry and environmental organisations concerning the reduction of the waste stream. The EC prefers this approach to the traditional process for legislative action because it assumes it is less time consuming, is based on consensus and is therefore more likely to be implemented. The Chlorinated Solvents Project started in early 1991 and is expected to continue well into 1993. The participants are all the trade associations representing manufacturers, users and disposers of chlorinated solvents, some member states, two NGOs and a group of European Commission officials. After three meetings, the group is still trying to get a proper overview of the current production, use and disposal of chlorinated solvents in the Community; it has also begun to review existing substitutes for chlorinated solvents. The preliminary reduction targets for chlorinated solvent waste by the year 2000 on the table are 35% reduction, 50% recovery - i.e. recycling and incineration with energy recovery - and 15% incineration (without energy recovery). 4.4 SHORTCOMINGS OF THE CHLORINATED SOLVENT PROJECT Progress has been very slow in the Project Group, particularly due to lack of access to information. Trade associations have consistently failed to provide critical information about the production, use and disposal of chlorinated solvents. In fact, the interests of the industries which produce and/or use solvents tend, if only because they outnumber the other participants, to dominate the process. Other interested parties, such as trade unions active in these industries or dry cleaning workers exposed to solvents, are not represented. More important is that the Project Group's mandate is too narrowly defined. "Accepting the inevitability that (chlorinated solvent) use will continue, the main aim should therefore be to control and minimize adventitious losses to the environment by promoting their use in closed systems and reduce waste streams, containing halogenated hydrocarbons, for disposal to a minimum," a recent draft analysis document states. In fact, by focusing exclusively on the waste stream rather than on the product itself or the problems associated with its use, such as volatile organic compounds, waste prevention through product substitution does not receive the required attention. In Greenpeace's view, the project should start with recognizing that chlorinated solvents pose a serious risk to human health and the environment as a product and as a waste, particulary through incineration, and that their production and use should be reduced and, ultimately, phased out. As the Project Group reaches its halfway point, there is not much hope that it will provide substantive results in this sense. In fact, as long as industry is not obliged to provide the data necessary to properly analyze the current state of the use of chlorinated solvents in the Community, the exercise remains futile. In addition, the question needs to be asked to what extent a voluntary agreement would be enforceable, and whether it is indeed preferable and more effective than legislation. The only certainty we have here is that such agreements withdraw important environmental issues from the democratic process. =end=