TL: OCEAN INCINERATION THE CASE FOR A GLOBAL BAN SO: Lisa J. Bunin, Greenpeace International (GP) DT: October 1988 Keywords: oceans toxics ocean incineration waste disposal bans europe ec gp reports / with contributions by Janus Hillgaard and John May Stichting Greenpeace Council Lewes, United Kingdom. Copyright (c) Stichting Greenpeace Council, 1988 All rights reserved. No reproduction, copy or transmission of this publication may be made without written permission. Such permission will not, however, be unreasonably withheld. 2nd Edition - October 1988 Published by Stichting Greenpeace Council 25-26 High Street, Lewes East Sussex BN7 2LU United Kingdom Phone +44-273-478787 Printed on Recycled Paper TABLE OF CONTENTS Ocean Incineration - The Case for a Global Ban What is Ocean Incineration? Why did Ocean Incineration begin in the first place? Where has Hazardous Waste been burned at sea? Table 1: Origin and Quantities of Waste delivered in 1985 Are there plans to end Ocean Incineration in Europe? How large is the ocean incineration fleet? Table 2: Ocean Incineration Vessels What international bodies regulate incineration at sea? Oslo Convention London Dumping Convention Which Conventions regulate ocean incineration elsewhere? Caribbean Pacific What new areas are being sought for Ocean Incineration? What are the major problems with Ocean Incineration technology? What are the alternatives to Ocean Incineration? Chlorinated Solvents Chlorinated Pesticides Polyvinyl Chloride (PVC) Will waste be reduced in Europe when Ocean Incineration ends? . What conclusions can be drawn about Ocean Incineration? Is the technology acceptable for less industrialized areas? What are Greenpeace's recommendations for action? Ocean Incineration Chronology of Events Greenpeace Submissions and Reports Ocean Incineration - The Case For A Global Ban When governments began regulating toxic pollution in the late 1960s, their programs focused on pollution control rather than on pollution prevention. Assuming that the environment could assimilate a certain amount of toxic pollutants without adverse effects, policy makers undertook to set "acceptable" levels for the release of a range of chemicals into the air, water and land. Most failed to fully anticipate, however, the cumulative and long-lasting effects of persistent and bioaccumulative substances on the environmental and human health. As synthetic products proliferated throughout the developed world, so did toxic waste streams and their associated disposal problems. For some waste types, incineration on land was the method of choice. But as manufacturers faced mounting regulatory compliance costs, closer government oversight and citizen opposition to siting new incinerators, ocean incineration emerged as the "alternative of least resistance." Introduced two decades ago, ocean incineration has been practised only in the North Sea, aside from a few test burns in the Gulf of Mexico and the South Pacific. Far from gaining wide acceptance as an environmentally sound method of toxic waste disposal, European governments have labelled the technology interim, pending the development of preferable options. This interim disposal method has served as a convenient escape route for the purveyors of inefficient production processes for nearly twenty years. Out of public view and control, the ocean remains attractive to industries struggling, in vain, to find a community willing to accept their toxic residues. The disposal technology offers a further attraction in that it is virtually liability-free. Any environmental damage resulting from ocean incineration operations cannot be linked to the original waste generator. It is unknown to what extent ocean incinerator emissions have affected the marine environment. But it is known that the types of chemicals burned at sea are some of the most toxic, persistent, bioaccumulative substances on earth. One such chemical, a fungicide called hexachlorobenzene, has recently been detected in elevated concentrations in the sediment of the North Sea burn zone. Scientists suspect that ocean incineration is a significant contributor to the build-up. Since the regional body which regulates ocean dumping in Europe, the Oslo Commission, has decided to terminate ocean incineration in 1994, the burnship industry has been seeking new markets and burn sites. Some proposed sites are located in the South Pacific, Caribbean and South East Asia, near countries not suffering from their own waste problems. This move typifies the rising trend in waste management. Companies from highly industrialized nations finding it increasingly difficult to secure disposal outlets for toxic, industrial waste in their own countries, have turned to developing countries to dump their unwanted, toxic effluent. The following discussion on ocean incineration is intended as an aid for policy makers, especially in regions where toxic waste disposal in general, and ocean incineration in particular, may become an issue in the near future. Legacies of toxic waste contamination around the globe corroborate the view that the earth cannot assimilate a limitless amount of toxic waste. Environmental indicators such as massive numbers of seal deaths in the North Sea and the unexplainable dolphin strandings off the east coast of the United States signal that the limit has already been reached in some parts of the world. In order to turn back the tide, industry must work to eliminate the volume and toxicity of waste it generates. The refusal of all nations to allow toxic materials to degrade the land and seas of the global commons is one certain way to force waste reduction and the use and development of more efficient production methods. What Is Ocean Incineration? Ocean incineration is a method used to dispose of toxic, persistent, industrial waste by burning it in shipboard incinerators and dispersing the residual matter into the atmosphere. The system is designed to burn liquid, pumpable, organic chemicals with a high caloric content, most notably organochlorines and other halogens. Wastes from the pesticide, plastic, pharmaceutical and wood preservative industries are among those commonly incinerated at sea. A relatively high proportion of the organohalogen waste is also generated by many small companies through their use of chlorinated solvents for cleaning and degreasing machinery. Why Did Ocean Incineration Begin In The First Place? Ocean Incineration was first proposed in 1969 by a company in the Federal Republic of Germany which specialized in the construction of land-based incinerators. The company had been experiencing continual problems with corrosion of its scrubbing system from the hydrochloric acid (HCl) and toxic by-products created during incineration. Engineers reasoned that this difficult and costly problem could be solved by removing the scrubbers. Thus, the industry proposed incinerating toxic substances at sea without the use of scrubbing devices, claiming that sea water would neutralize the acid and dilute the remaining toxic by-products of combustion. Where Has Hazardous Waste Been Burned At Sea? Currently, no ocean incineration takes place outside the North Sea. The latest year for which data on ocean incineration operations are available is 1985. As the figures in Table 1. (omitted here) indicate, the Federal Republic of Germany generates by far the highest volume of waste burned at sea: more than half. Switzerland and Belgium, respectively, incinerate the next largest amount followed by France, Norway, Italy, the Netherlands the United Kingdom, Austria and Spain. The total amount incinerated annually equals approximately 105,000 tonnes. Between 1974 and 1983, sporadic test burns have been conducted by the United States in the Gulf of Mexico and in the Pacific, off the Johnston Atoll near Hawaii. The last test burn occurred in 1983. Two subsequent burn proposals were scrapped by the government in 1983 and 1985 because of unresolved scientific, technical and legal questions surrounding the technology and intensive public protest. The stalled program was finally cancelled in January 1988 when the United States Congress cut its funding. Nearly 5,000 tonnes of chemical waste were burned off the Australian coast by the incinerator vessel Vulcanus I in 1982. In 1983, an additional 220 tonnes were burned there. At that time, no regulations existed to govern operations in Australia. Although the government has since developed operational requirements, no other burns have occurred off the coast. Are There Plans To End Ocean Incineration In Europe? Norway and the Netherlands have committed themselves to terminating the use of ocean incineration in 1989 and 1990 respectively. North Sea States have agreed to reduce the amount of waste they burn at sea by 65 percent in 1990 and to discontinue operations completely by 1994. Since ocean incineration is banned in the Baltic Sea, under the Helsinki Convention, and in the Mediterranean, by Contracting Parties to the Barcelona Convention, it will effectively be prohibited in all European waters as of 31 December 1994. How Large Is The Ocean Incineration Fleet? The three currently operational burnships are Vulcanus I, registered in Singapore, Vulcanus II, registered in Liberia and Vesta, registered in the Federal Republic of Germany. Antwerp, Belgium, is the receiving port for 80 percent of Europe's waste incinerated at sea. The two Vulcanus ships are owned by Ocean Combustion Services (OCS), a division of United States based conglomerate, Waste Management, Inc., the largest hazardous waste disposal company in the world. Lehnkering of the Federal Republic of Germany owns and operates Vesta. Table 2. (omitted here) lists the ships equipped to incinerate toxic waste at sea. Which International Bodies Regulate Incineration At Sea? Ocean incineration is regulated under two international conventions that were formalized in the mid 1970's: - The Convention on the Protection of Marine Pollution by Dumping of Wastes and Other Matter, commonly known as the London Dumping Convention (LDC). - The International Agreement on the Prevention of Marine Pollution by Dumping from Ships and Aircraft, commonly known as the Oslo Convention (OSCOM). The London Convention is a world-wide agreement while the Oslo Convention covers the North Sea and the Atlantic Ocean bordering northern Europe. Oslo Convention In 1977, the Oslo Commission adopted a Code of Practice for the control of incineration at sea. Four years later, in 1981, the Commission added a set of "Rules on Incineration at Sea," known as Annex IV to the Convention. The Annex states that ocean incineration shall be regarded as an interim method of waste disposal and requires that countries promote the further development of alternative land-based methods. It prescribes that Contracting Parties deny permits for incineration at sea of substances and materials for which practical alternative land- based methods exist. Annex IV further states that, "the Commission shall meet before January 1990 to establish a final date for the termination of incineration at sea." At its annual meeting in June 1988, the Oslo Commission decided to ban ocean incineration in the North Sea and North Eastern Atlantic Ocean by the end of 1994. North Sea states further agreed to reduce the amount their countries incinerate at sea by 65 percent by the close of 1990. London Dumping Convention Developments at the London Dumping Convention (LDC) took a similar course. At the first Consultative meeting in 1976, Contracting Parties acknowledged the need for special provisions to prevent marine and atmospheric pollution from ocean incineration operations. In 1978, the LDC decided to create a legal instrument for the control of ocean incineration on a global basis. The resulting document, called "Regulations for the Control of Incineration of Wastes and Other Matter at Sea", refers to incineration at sea as an "interim method of disposal of wastes pending the development of environmentally better solutions, considering at all times the best available technology." The document further stresses that ocean incineration should only be used as a last resort and should not discourage progress toward "environmentally better solutions including the development of new techniques." A resolution calling for a 1 ban on ocean incineration was adopted by the Eleventh Consultative Meeting of Contracting Parties to the LDC in October 1988. In accordance with the terms of the resolution, all signatories to the Convention are obligated to phase-out ocean incineration by the close of 1994. Which Conventions Regulate Ocean Incineration Elsewhere? Caribbean The 1983 Convention for the Protection and Development of the Marine Environment in the Wider Caribbean region, known as the Cartagena Convention, provides a legal framework for dealing with ocean dumping and pollution under the United Nations Environmental Program's Caribbean Action Plan. At the Convention's first plenary session in October 1987, participants expressed concern about the possibility of waste being imported into the region from countries outside the Convention area. Venezuela and other countries introduced a resolution prohibiting ocean incineration. In the spirit of compromise during this initial official gathering, however, Contracting Parties agreed to much weaker language. Their Resolution, in Annex XII, simply urges States and territories to, "refrain from authorizing the disposal [of wastes] at sea," except "in accordance with global rules and standards established by the London Dumping Convention." Venezuela and the other supporting countries have said that they intend to submit a stronger proposal at the next meeting of the Contracting Parties in September 1988. Pacific The Convention for the Protection of the Natural Resources and Environment of the South Pacific, under the South Pacific Regional Environmental Program (SPREP), provides a legal basis for jurisdiction over ocean dumping. Although the SPREP Action Plan does not specifically regulate incineration at sea it does urge, in Article 10, that all appropriate measures are taken to "prevent, reduce and control pollution in the Convention Area caused by dumping." Over the last several years, there have been a series of intergovernmental meetings to discuss the Action Plan; however, the Convention itself has not officially entered into force. At the SPREP meeting in November 1985, the delegation from Fiji introduced a resolution calling for the prohibition of incineration at sea. The United States delegation managed to stifle all discussion of the resolution, presumably to preserve this disposal option for their waste in the Pacific. No other action has been taken regarding the resolution since. What New Areas Are Being Sought For Ocean Incineration? Following the decision by the Oslo Commission to ban ocean incineration in Europe, the industry has been attempting to re- establish its technology elsewhere. Ocean Combustion Services (OCS), has already begun courting governments in the Caribbean, South Pacific and South-East Asia. Representatives of OCS presented two proposals to local governments in Auckland and Wellington, New Zealand in June 1987. One proposal involved sending an incinerator vessel to New Zealand to burn existing stockpiles of PCBs in the South Pacific. The second involved collecting waste from New Zealand, storing it at a facility currently under construction in Portugal and then burning the waste in either the Atlantic or North Sea. After OCS' subsequent visit to Australia, government officials in the New South Wales area expressed an interest in using ocean incineration to dispose of 9,400 tonnes of intractable toxic waste currently stored in steel canisters. No action has been taken there thus far and government officials deny wanting to pursue the option further. Waste Management, Inc., (WMI) the parent company of OCS, has been gaining a financial foothold in the Pacific by acquiring interests in Australian and New Zealand based waste disposal companies. It has become a major shareholder in the waste disposal and hauling company, Waste Management (NZ) Ltd. and two WMI representatives sit on the Board. Revenues from Pacific Waste Services (PWS) and Tiger Waste Control, Australian wholly- owned subsidiaries of WMI, account for 4 percent of the total revenue of WMI. This share could be increased substantially if an incineration vessel were imported into the region. PWS also holds 40 percent of the shares in Waste Management (NZ) Ltd. on behalf of WMI. Although OCS' plans for the Caribbean and South East Asia have not been made public, WMI admits to contacting local governments and industry to assess the waste market and potential for port side storage facilities. What Are The Major Problems With Ocean Incineration Technology? No incineration process can operate with an efficiency of 100%. Therefore, some portion of the original chemicals fed into the system is always released into the marine environment. The industry claims that more than 99 percent of the toxic compounds are destroyed in the incineration process, based on emissions testing for a few preselected compounds. But as experts at the 1987 LDC/Oslo Commission Meeting of Experts on Incineration at Sea have pointed out, this system of monitoring is inaccurate because it fails to account for the known synthesis of new compounds, many of which are even more toxic and persistent than their parent compounds. In fact, the method by which incinerator efficiency is currently measured was severely criticized by H. Compaan, a scientific consultant to the ocean incineration industry. He hypothesized that even if the waste were transformed entirely into dioxins -- the most potent class of toxins known -- the operation could be rated as having been "carried out perfectly with a DE [destruction efficiency] of 100 percent." Compaan noted that "this will never happen," but cited it as an illustration that the measurement methodology "is of limited value in protecting the sea." A further limitation of the destruction efficiency claim of 99 percent is that it does not account for chemicals formed "after the stack" --that is, in the exhaust gas which has left the incinerator. All past samples from ocean incinerators have been taken at the funnel of the incinerator where the gas temperature is very hot, ranging between 1,000øC and 1,100øC. Yet chemicals continue to recombine until the gas has nearly cooled, at approximately 180øC. Actual measurements taken from operational incinerators, such as the SAKAB facility in Norrthrup, Sweden, have repeatedly confirmed that this is the case. There has never been a complete analysis of the full range of chemicals emitted from incinerator stacks The Science Advisory Board of the U.S. Environmental Protection Agency has expressed doubts that such an analysis is even possible. Even so, during the few cursory studies conducted, some notable toxic, persistent chemicals have been detected in the incinerator emissions. One particularly lethal class of dioxins, polychlorinated dibenzo-p-dioxins (PCDDs) was detected in the incinerator exhaust gas of Matthias II. As a result, the Federal Republic of Germany revoked the vessel's operating permit, permanently. Another highly toxic class of chemicals, dibenzofurans, was detected in stack gas samples during the incineration of highly toxic polychlorinated biphenyls (PCBs) in the Gulf of Mexico in 1982. Virtually no new published test results have been released by the incinerator company since 1983. Like all technological systems, ocean incinerators are prone to breakdowns. "Flameouts" is the trade term used when a burner clogs or when its flame is extinguished. When surges in the waste feed system do occur, incinerator operators are allowed under present regulations, to discontinue monitoring parameters used to calculate destruction efficiency. As a result, no data exists regarding chemicals emitted during less than optimum conditions. The frequency of such "flameouts" is unknown. They have been documented only on the few occasions when independent observers have been on board an incineration vessel. Ocean incineration frequently requires the long distance transport of hazardous waste, on land and at sea, which creates the potential for chemical spills. In order to fill one burnship, hazardous waste often must be transported from many different regions to the few ports licensed to handle and load hazardous wastes. The obvious problem with this system is that the further the waste is moved away from the original generator, the greater the chance of a spill. The potential for a full-scale catastrophe in port or at sea is always present. Authorities who have looked into this issue consider the likelihood of a complete loss of cargo at sea remote. They see a much greater risk of a smaller but nevertheless damaging spill. Maritime officials in the United States have publicly acknowledged that if a hazardous waste spill occurred at sea, it would be nearly impossible to recover even a small quantity of waste. The U.S. Environmental Protection Agency concluded in its 1985 Environmental Impact Statement on the North Atlantic burnsite that if a spill occurred, "... near coastal, recreational, or commercial activities, a serious public health hazard could result .... [and] considerable biomass would probably be destroyed. Clean-up would be difficult and expensive, if possible at all. Effects of contamination could be widespread and possibly long-lasting." It is difficult to test, verify or limit the types of waste to be burned at sea. Few samples are taken of the waste loaded on incinerator vessels. Thus, the exact nature of the waste cannot be known prior to incineration. At the scientific meeting of the Oslo Commission in March 1988, this point was underscored by the Federal Republic of Germany. It admitted that it was not possible to check each waste stream delivered for ocean incineration, due to lack of resources. During one incident on May 31 1987, the Belgian police served a warrant against Ocean Combustion Services (OCS) for illegally importing over 3,000 tonnes of PCB-contaminated waste from Italy. OCS attempted to dilute the waste with other waste to reduce the PCB-concentration below the required limits. The company sent an estimated 2,500 tonnes of waste back to Italy on July 18th. The rest was diluted below the detectable limits for PCBs and burned at sea. In another case the incinerator vessel owner, Waste Management, Inc., denied burning waste contaminated with dioxins in the Gulf of Mexico in 1981/82. It was not until the original waste generator disclosed that the waste was indeed dioxin- contaminated that its specific chemical contents were substantiated. This situation raises legitimate concern about the potential for prohibited or "blacklisted" waste to be burned at sea. Despite nearly twenty years of use, and limited research, no definitive statement on the environmental safety of ocean incineration can be made. A thorough analysis of the acute and chronic effects of ocean incineration emissions on the marine environment has not been carried out or even attempted. Two short-term studies were conducted in the United States; one on fish (Fundulus grandis) exposed to emissions in the Gulf of Mexico (1977) and one on plankton in the incineration zone of the South Pacific (1978). In both studies some changes were observed in the exposed species but the results were inconclusive. Preliminary results of an ongoing study conducted by the German Hydrographic Institute indicate that there is a build-up of the fungicide, hexachlorobenzene (HCB), in the sediment of the North Sea burn zone. HCBs are not only burned at sea but they are also synthesized during the incineration of organohalogens. In 1987, the Federal Republic of Germany's delegation to the LDC/OSCOM Meeting of Experts on Incineration at Sea disclosed this finding with a qualification that it was too soon to draw any definitive conclusions. In a study published by the University of Hamburg, Germany, a year later it stated that, "a plausible explanation for the high HCB levels is the fact that the area coincides almost exactly with the hazardous wastes incineration area." The types of waste burned at sea are known to adversely affect living organisms. When released into the environment, even in small quantities, organohalogens can disrupt sensitive ecosystems. Since they are more soluble in fat than water, organohalogens are readily absorbed in the fatty tissues of living organisms. For the most part, these highly toxic compounds resist natural degradation, persist indefinitely and recycle continuously through the air, water and food chains. This accounts for the heavy doses of organohalogens often found in sea birds, marine mammals and even humans. During ocean incineration operations, the fatty-rich film overlaying the surface of the ocean, known as the marine microlayer, is the first area impacted. The miniscule, 50 microns thick micro layer provides a conducive environment for the concentration and bioaccumulation of fat soluble organohalogens. Since the vicinity of the microlayer serves as a spawning and feeding ground for larvae and juvenile forms of fish, it provides a convenient entry route into the food web. The overall productivity of the marine environment diminishes with the accumulation of toxic persistent compounds - organohalogens. Even minute concentrations of organohalogens have been known to result in abortions, fetal toxicity, fetal resorption and cancer. Sublethal effects include reproductive system damage and dysfunction, liver and kidney damage and dysfunction, immunosuppression, skin ulcerations and behavioral problems. Juvenile forms of marine life seem to be more susceptible than adults, and this can seriously affect the population dynamics of some organisms. Organohalogens gradually become more concentrated (biomagnified) as each trophic level in the food chain. Biomagnification leads to heavy burdens of persistent, toxic chemicals in top marine predators. Humans accumulate toxic pollutants from their diet. Those populations which consume large quantities of fish have been found to contain high concentrations of organohalogens in their bodies. That is why in certain heavily polluted areas people are warned to minimize their consumption of local fish. The availability of ocean incineration serves as a disincentive for the reduction of toxic persistent waste at the manufacturing process level and perpetuates its unnecessary production. Currently ocean incineration is being used because it is readily available and not because it is an environmentally desirable disposal option. As long as ocean incineration can be used, it win be used because it is more convenient than searching for new ways to eliminate waste in the production process. In that way, the availability of ocean incineration perpetuates waste production and sanctions the wasting of resources, which could otherwise be reused, recycled or transformed into another product. What Are The Alternatives To Ocean Incineration? The best alternatives to ocean incineration are manufacturing process modifications which result in the elimination of toxic waste by individual plants. Such changes have been successfully instituted by hundreds of companies throughout the world, who have minimized their waste generation by maximizing their resource efficiency. Specific technological approaches which have been proven to minimize toxic waste generation include process reformulation, chemical product substitution, and a variety of maintenance, operational and housekeeping changes, as well as waste recycling. At the LDC/Oslo Commission Meeting of Experts on Incineration at Sea participants produced a chart which demonstrated that substitute technologies exist for every single chlorinated waste stream currently burned at sea. The following discussion provides three examples of how such techniques can be put into practice to eliminate or substantially reduce waste by changing production and use practices. Chlorinated Solvents A steel company in Sweden developed a new concept for degreasing and cleaning steel components. Instead of using the solvent, trichloroethylene, for cleaning machines it installs new washers that use water and alkaline detergent instead. This practice eliminates the liquid waste stream containing an estimated 80 tonnes of the chlorinated solvents per year. In the end, the water is removed in a dehydrator bath. Both the dehydrator (low- aromatic naphtha) and the water are recycled after filtering. The first three of these new washers were rebuilt from old ones. Following their success the company plans to start production of a completely new line of machines in the summer of 1988. This new cleaning system will also be introduced into all the company's own plants world-wide. Product development is costing the company $ 1 million but the cost is more than offset by the savings. The company saved $80,000 per year in one plant alone. Other companies have already expressed interest in purchasing the new system. Chlorinated Pesticides Halogenated pesticide production represents an industry in which environmentally sound substitutes are readily available. These "designed to kill" substances can be replaced by alternative methods of agricultural production rather than alternative chemicals. Chemical-free agriculture is more labor intensive but uses less non-renewable energy. Thus, farmers can actually save money and energy, and boost local employment. This type of farming also eliminates the contamination problems associated with crop spraying such as human poisoning and contamination of drinking water. Classical biological control methods for farming do not require the use of synthetic compounds either. This technique supports the principle of introducing predators to prey on the most insidious insects which threaten to infect certain crops. Again, it eliminates the need to use toxic, persistent chemicals. This type of agriculture must be practiced with extreme care and precision to avoid tipping the ecological balance and creating another dominant, yet undesirable insect. In Indonesia, this system of agriculture has been successfully put into practice. After discovering that the country's heavy reliance on pesticides was causing the propagation of resistant strains of "super-pests" in increasing numbers, the government decided to ban the use of 57 pesticides on rice fields. After 18 months, farmers using reduced pesticide techniques realized a 16 percent better yield. Agricultural production costs for farmers fell substantially and the government saved almost $50 million in pesticide subsidies. Polyvinyl Chloride (PVC) Residues from the manufacture of polyvinyl chloride (PVC) comprises of a large portion of hazardous waste burned at sea. Products which contain PVC include construction materials, packaging, electrical wire and cable insulations, household furnishings and automobile parts. The best way to eliminate the PVC waste problem is to eliminate the use of the product, whenever possible. This includes minimizing the used of PVC packaging by substituting biodegradable, recycleable and reusable materials. Common non- halogenated substitutes include paper, glass, waxed cardboard, ceramic, steel, copper, aluminium and polystyrene. Will Waste Be Reduced In Europe When Ocean Incineration Ends? Waste prevention and recycling will be emphasized by governments during the phase-out of ocean incineration in Europe. Several governments such as the Netherlands and the Federal Republic of Germany have already made this a priority option for their research and development programs. The FRG expects that no wastes from large-scale waste generators will be incinerated at sea after 1990. Waste streams produced by a great number of small firms are expected to be recycled rather than landfilled or burned. As the end date for ocean incineration in the Netherlands nears, plans to enhance pollution prevention and recycling efforts have increased. The Dutch government is in the process of identifying organohalogen waste streams and investigating substitute products, processes and technologies. The trend towards waste reduction is further corroborated by the latest figures available to the Oslo Commission on ocean dumping and alternative options, submitted by North Sea States in June 1988. These figures project that the quantity of chlorinated wastes being incinerated on land in 1995 will be the same as in 1987. Also, the quantity of waste recycled or which ceased to be produced due to more efficient production in 1987 (40,000 tonnes) will rise to 133,000 tonnes in 1995, when ocean incineration ceases to be a disposal option. What Conclusions Can Be Drawn About Ocean Incineration? Evidence against the environmental acceptability of ocean incineration is accumulating. As the technology is scrutinized more closely, it is clear that ocean incinerators emit toxic chemicals into the environment. It is further evident that the quantity and toxicity of emissions has been repeatedly underestimated and the dangers underplayed. The invariable reformation of new compounds, even more toxic and persistent than their parent compound, present a serious issue of concern, given the large chlorine source available in the unscrubbed gases of ocean incinerators. Although the effects of such emissions are unknown because they have not been properly studied by industry or government, sufficient research exists on dangers associated with the types of toxic, persistent bioaccumulative substances burned at sea to warrant eliminating the threat. The use of ocean incineration as a disposal technology must be terminated at the earliest opportunity. Is The Technology Acceptable For Less Industrialized Areas? If ocean incineration is not acceptable for European Seas, then it is certainly not acceptable for the seas of the Pacific, Caribbean, South East Asia or any other area where the oceans are the lifeblood of its inhabitants. The importation of such a high volume technology to a country or region which does not generate a large quantity of toxic waste will inevitably lead to the influx of waste from other countries. (It takes approximately 30,000 tonnes of industrial toxic waste per year to keep one ocean incineration vessel operational and profitable). This situation warrants careful attention, given the escalating number of reported cases of illegal toxic waste imports to developing countries. The international toxic waste trade business is on the upsurge because industrialized countries plagued with contaminated sites from inadequate waste disposal methods of past, find it increasingly difficult to secure ways to dispose of their toxic residues. As national environmental laws become more stringent to prevent future toxic legacies, compliance with waste disposal laws has becomes difficult and costly. Thus, industry turns to the less developed nations for assistance by offering them attractive economic incentives to accept and dispose of their waste. Oftentimes, these same countries with colonies in the developing world such as the United Kingdom, United States, France and the Netherlands use their influence in regional for a in the Caribbean, Pacific and South-East Asia to block restrictive ocean dumping measures. While reserving the possibility of employing certain less desirable disposal options in countries eager to secure new profitable commercial ventures, these same countries support a prohibition of such practices in their own seas in Europe and North America. Although this is done under the auspices of preventing even worse disposal methods such as direct dumping, it also opens up the potential for the international trade in waste from highly industrialized countries to less developed ones. In the wake of the Bhopal disaster and in the light of the moves by the industry to export banned technologies to other parts of the world, a new environmental ethic is needed. Technologies outlawed in other parts because they fail to meet existing environmental standards must not be allowed to be exported to areas with less developed standards. The responsibility for maintaining this ethic rests with the exporting country. What Are Greenpeace's Recommendations For Action? ù Prohibit ocean incineration of toxic waste in all seas of the world. ù Ensure that appropriate steps are taken to eliminate the waste currently burned at sea. Any remaining effluent should be reused or recycled. ù Prohibit waste currently burned at sea from being exported to other countries for disposal. ù Promote the transfer of no-waste/low-waste technologies to developing countries instead of substandard toxic waste disposal methods. ù Develop a widely publicized, easily accessible international information exchange network on low-waste and no-waste technologies. Ocean Incineration Chronology Of Events 1969 FRG registered tanker fitted with an incinerator, Matthias I, is the first ship to burn toxic, organohalogen waste in the North Sea. In the years that follow, five additional vessels conduct burns in the North Sea: Mattias II & III, Vesta & Vulcanus I & II. 1972 Ocean Combustion Services (OCS) conducts its first burn in the North Sea with the retrofitted incinerator vessel, Vulcanus I. 1974 Shell Chemical Company hires Vulcanus I to burn four shiploads of toxic waste in the Gulf of Mexico. 1976 US government publishes final Environmental Impact Statement on the Gulf of Mexico which leads to the official designation of the Gulf burnsite. 1977 Vulcanus I is barred from the port of Emden, Germany, because of chemically contaminated bilge water. The vessel leaves port and the fate of the bilge remains unknown. Shell burns four more shiploads of toxic waste in the Gulf. OCS employs Vulcanus I to burn two shiploads of Agent Orange, previously stored by the US Army, off the Johnston Atoll in the South Pacific near Hawaii. Over 270 pounds spill into the Atlantic Ocean at dockside during loading. 1978 London Dumping Convention (LDC) issues international ocean incineration regulations stating that the practice should be viewed as an "interim" measure, pending the development of preferable options. 1979 FRG confirms reports that burning organohalogens results in the formation of new toxic chemicals, seven of which are detected in the emissions of the FRG registered ship, Vesta. 1980 Waste Management, Inc., the world's largest hazardous waste disposal firm, buys OCS. 1981 Vulcanus I is barred from the Netherlands because of cargo tank leaks. Oslo Commission decides to meet before 1990 to set a date to end ocean incineration operations in the North Sea. Corruption charges are levied as Waste Management, Inc.'s attorney reportedly writes permit conditions for Vulcanus I burns in the US, while simultaneously working under contract with the US Environmental Protection Agency. First PCB burn is conducted on board Vulcanus I in the Gulf of Mexico. Shipboard engineers report severe vibrations in the incinerator; problems with plugged sampling tubes and loss of test samples. The burn is labelled "invalid" by government officials who call for additional test burns. 1982 US Maritime Administration announces it will use taxpayers' money to guarantee loans to finance the construction of two new incinerator vessels, Apollo I and Apollo II. Vulcanus II is launched in Europe. A second PCB burn in the Gulf of Mexico and the first public hearing on ocean incineration occur simultaneously in the US. Public pressure from South Texas and Louisiana citizens and Greenpeace forces the Environmental Protection Agency to cancel a third PCB burn. US government investigation reveals that the permit for Vulcanus I to incinerate only "PCBs in fuel oil" was changed at the last moment to include "other organic components." No one admits to changing the permit. The investigative team concludes that "the company knew that the waste was contaminated with dioxin but failed to conduct proper tests" but no legal action is taken against the company. 1983 Dioxin is detected in the emissions of Matthias II. FRG authorities revoke the vessel's operating permit. Chemical company, ICI, hires Vulcanus I to burn organohalogen waste off the Australian coast of New South Wales. No government oversight takes place because no regulations exist to control and monitor ocean incineration operations under Australian law. Greenpeace members on board Vulcanus II observe a burn of organohalogen in the North Sea. Photographs taken show flames shooting above the stack and emissions of black smoke indicating an inefficient burn. 1984 US denies permit to Waste Management, Inc., but calls for the development of a comprehensive ocean incineration program, to be carried out at burnsites off the East, West and Gulf coasts. US Environmental Protection Agency meets with industry and environmentalists, ostensibly to seek assistance in drafting ocean incineration regulations. At the second meeting, participants learn that the government has already drafted regulations. Greenpeace again photographs black smoke and flames emitted during a burn on board Vulcanus II. 1985 A bill, calling for a moratorium on ocean incineration and a study to assess the potential for hazardous waste reduction is introduced into the US Congress by thirty Representatives. Owner of Apollo I and II, At-Sea Incineration, files for bankruptcy. 1986 Several thousand people attend hearings in four states to protest against the proposed burn off the East coast of the US. Over 15,000 signatures are collected in opposition to the burn and the local mayor threatens to blockade Vulcanus I with fishing and pleasure boats. US again denies permit to Waste Management, Inc., citing scientific, technical and legal problems and public opposition. 1987 At a meeting of the Oslo Commission, Nordic countries submit a proposal to terminate ocean incineration in the North Sea by December 31 1991. The proposal is blocked by Ireland, UK, Spain and Portugal. US renews plans to designate four burnsites by the end of 1989. On May 31st, Antwerp police serve a warrant against OCS for illegally importing 3,170 tonnes of PCB contaminated waste from Italy. After attempts to dilute the PCB concentration in the waste below the administrative limit fail, OCS is ordered to return 2,513 tonnes of it to Italy. The remaining waste is diluted and subsequently burned at sea. Flotilla of 35 Danish fishing vessels and the Greenpeace vessel, SIRIUS, protest against ocean incineration in the North Sea off the coast of Rotterdam. The furnaces of the incinerator vessel, Vulcanus II, are forced to shut down when the ship's propeller becomes entangled in a fishing net. National Union of Seamen in the UK and the National Federation of Fishers, in Denmark, launch campaigns to end ocean incineration. Local citizens, fishing unions, politicians and Greenpeace successfully block port-side storage facility proposals for toxic wastes to be burned at sea, in North Shields, England and Vlissingen in the Netherlands. Spain cancels plans to burn toxic waste at a new burnsite off the North Atlantic coast in Asturias. The Minister of the Environment cites "the special sensitivity shown by the public in relation to this issue, and the wishes of the government to protect the marine environment" as the rationale for their decision. Australia announces its intention to investigate the feasibility of using a high-temperature incinerator ship to burn hazardous waste. European Parliament passes a resolution in support of terminating ocean incineration in the North Sea by 1990. North Sea Ministers at their annual conference unanimously agree to terminate ocean incineration of industrial waste by 31 December,1994, with a reduction of not less than 65 percent by the end of 1990. 1988 Waste Management, Inc., abandons plans to burn toxic waste in US waters after eight years of unsuccessfully trying to establish a large-scale ocean incineration business there. US Environmental Protection Agency cancels its entire ocean incineration program, based upon the recommendation of Congress. Spain designates a new burnsite 300 miles southwest of the Irish coast in the Atlantic Ocean. It is still unclear whether Spain will use this vulnerable site, situated in the Gulf stream. OCS signs a contract with Spain for the incineration of 20,000 tonnes of waste. In June, 1900 tonnes are burned on the North Sea despite protests from the Nordic countries and North Sea fishermen. Contract between OCS and an Antwerp storage facility expires. OCS is unable to negotiate contracts with other storage facilities. In Antwerp, Belgium, waste is loaded on board Vulcanus II directly from barges sent from FRG. Oslo Commission agrees to terminate ocean incineration in the North East Atlantic Ocean, bordering Europe, no later than 1994. Several countries express the view that ocean incineration could end before then, as the planned reductions by 1991 of waste amounts would make it unprofitable. Danish government submits a resolution to the London Dumping Convention calling for an end to ocean incineration in the North Sea by the end of 1990 and a prohibition on the use of the technology in any new areas. LDC adopts a compromise version of the Danish resolution, requiring the phase-out of ocean incineration by 31 December 1994. Greenpeace Submissions And Reports Testimony Before the U.S. Environmental Protection Agency: Review of the Draft Permit for Ocean Incineration Aboard M/T Vulcanus, August 31, 1982. Testimony Before the U.S. Environmental Protection Agency on the Proposed Designation of the North Atlantic Incineration Site, April 14, 1983. Submission to the Joint Hearing on the Ocean Incineration of Hazardous Waste at Sea, Subcommittee on the Fisheries and Wildlife Conservation and the Environment and the Subcommittee on Oceanography, U.S. House Committee on Merchant Marine and Fisheries, December 7, 1983. Testimony on Ocean Incineration Presented to the U.S. Congress Environment, Energy and Natural Resources Subcommittee of the Committee on Government Operations, July 12, 1984. Presentation to the Standing Advisory Committee for Scientific Advice (SACSA) of the Olso Commission, Hamburg, March 19, 1985. Submission to the U.S. Environmental Protection Agency on the Ocean Incineration of Toxic Waste and Proposed Regulations, June 28, 1985. Testimony on Ocean Incineration (H.R.1295) Presented to the U.S Congress Subcommittee on Oceanography, Committee on Merchant Marine and Fisheries, November 11, 1985. Testimony Before the U.S. Environmental Protection Agency Regarding the Proposed Research Permit for Ocean Incineration of Hazardous Waste by Chemical Waste Management, Inc. January 27 1986. Report commissioned by Greenpeace: "Ocean Incineration of Hazardous Waste: A revisit to the Controversy," Edward Kleppinger & Desmond Bond. Submitted to the Scientific Group on Dumping Meeting of the LDC. LDC/SG.9/INF.5. 28 April - 2 May 1986. Submission to the Scientific Group on Dumping meeting of the LDC: Terms of Reference for the Joint LDC/OSCOM Experts Meeting on Ocean Incineration. LDC/SG.9/WP. 28 April - 2 May 1986. Submission to the 10th Consultative Meeting of Contracting Parties to the London Dumping Convention on Incineration at Sea. LDC 10/INF.12. October 1986. Submission to the Joint LDC/OSCOM Group of Experts on Incineration at Sea, 2nd Meeting: "Scientific and Technical problems related to incineration at sea, in particular with regard to control and monitoring requirements". LDC/OSCOM/IAS 2/6. 27 April - 1 May 1987 Presentation on Incineration at Sea to the Oslo Commission. Cardiff, Wales. June 1987. Submission to the Joint LDC/OSCOM Group of Experts on Incineration at Sea, 2nd Meeting: "Unneeded Technology Poses Unacceptable Environmental Hazards". LDC/OSCOM/IAS 2/INF 3. 27 April - 1 May 1987. Submission to the Scientific Group on Dumping Meeting of the LDC: "Comments on section 2 of the Joint LDC/OSCOM Report on Ocean Incineration (LDC/OSCOM/IAS 2/9)". LDC.SG 11/2/5. 25 - 29 April 1988. Report commissioned by Greenpeace: "Ocean Incinerators for Chlorinated Waste", Lars Stromberg. Submitted to the Scientific Group on Dumping Meeting of the LDC. LDC/SG/11/2/6. 25 - 29 April 1988. Report commissioned by Greenpeace: "Chlorinated Environmental Pollutants Emitted from Ocean Incineration Stacks",Jorgen R. Petersen. Submitted to the Scientific Group on Dumping Meeting of the LDC. LDC/SG 11/2/7. 25 - 29 April 1988. Report commissioned by Greenpeace: "Mechanisms of Transport of Organochlorine Residues after Incineration to Air, Water, Microlayer and Organisms", Anders Sodergren, Per Larsson and Johan Knulst. Submitted to the Scientific Group on Dumping Meeting of the LDC. LDC/SG 11/2/8. 25 - 29 April 1988. Submission by Greenpeace to the Scientific Group on Dumping Meeting of the LDC Comments on LDC/SG 11/INF.9 "Consideration of the Report of the Joint LDC/OSCOM Group of Experts on Incineration at Sea - Comments on LDC/SG 11/2/5, LDC/SG 11/2/6, LDC/SG 11/2/7 and LDC/SG 11/2/8". LDC/SG 11/WP.3. 25 - 29 April 1988. Presentation to the Oslo Commission on Incineration At Sea. Lisbon, Portugal. June 1988. Report commissioned by Greenpeace "Transport Mechanisms of Organochlorine Residues after Incineration to Air, Water, Microlayer and Organisms". Anders Sodergren; Per Larsson and Johan Knulst. September 1988. All documents are available upon request from Greenpeace International, 25-26 High Street, Lewes, E. Sussex, BN7 2LU, UK.