Regional Strategy for ESM of ULAB - UN Environment · REGIONAL STRATEGY FOR THE ENVIRONMENTALLY SOUND ... National Office of Pollution Prevention ... Regional Centre in Trinidad and

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PRELIMINARY DRAFT FOR COMMENT

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REGIONAL STRATEGY

FOR THE ENVIRONMENTALLY SOUND MANAGEMENT OF USED OILS IN THE

CARIBBEAN ISLAND STATES

(PHASE II – STRATEGY DEVELOPMENT)

8 December 2006

PREPARED BY

Michael VanderPol

Environment Canada, National Office of Pollution Prevention (on assignment to UNEP-Secretariat of the Basel Convention)

351 St. Joseph Blvd

Gatineau, Quebec, Canada K1A 0H3

Phone: (819) 953-9246 Email:

[email protected]

ACKNOWLEDGEMENTS This project work was funded under the Strategic Plan for the Implementation of the Basel Convention to 2010. This project is being carried out by the Basel Convention Regional Centre in Trinidad and Tobago and the Secretariat of the Basel Convention under the United Nations Environment Programme (UNEP). Many stakeholder organizations contributed information leading to the development of this Regional Strategy. They are listed below in alphabetical order: Government Organizations

Basel Convention Regional Centre, Caribbean (BCRC-CARIBBEAN), Trinidad and Tobago Caribbean Industrial Research Institute (CARIRI), Trinidad and Tobago Department of Environment, Bahamas Department of Environment, Belize Department of Environmental, Bahamas Environment Health Department, Dominica International Maritime Organization Ministerio de Ciencia, Tecnología y Medio Ambiente (CITMA), Cuba Ministry of Agriculture, Lands, Marine Resources, Environment, Agro-Industry and National

Parks, Antigua and Barbuda Ministry of Health and the Environment, St. Kitts and Nevis Ministry of Health, Sports and Youth Affairs, Antigua and Barbuda Ministry of Health, St. Vincent and the Grenadines Ministry of Housing, Lands and the Environment, Barbados Ministry of Local Government and Environment, Jamaica Ministry of Natural Resources, Environment, Commerce and Industry, Belize Ministry of Physical Development, Environment and Housing, St. Lucia Ministry of Public Utilities and Environment, Trinidad and Tobago Secretaría de Estado de Medio Ambiente y Recursos Naturales, Dominican Republic Solid Waste Management Authority, St. Lucia UNEP Regional Seas Programme, Secretariat of the Cartagena Convention (CAR/RCU)

Industry organizations

Dominica Solid Waste National Corporation Electricity Services Ltd. (VINLEC), St. Vincent and the Grenadines National Petroleum Marketing Company Limited, Trinidad & Tobago Oil Mop Environmental Services Ltd., Trinidad & Tobago

Academia

University of the West Indies, Trinidad & Tobago Environmental Non-government Organizations

Caribbean Environmental Health Institute (CEHI), St. Lucia Environment West Indies (EWI), Martinique

Sponsors

Basel Convention Regional Centre for Training and Technology Transfer for the Caribbean Region (BCRC-Trinidad and Tobago)

Environment Canada (in-kind support)

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PREAMBLE The Regional Strategy for the Environmentally Sound Management of Used Oils in the Caribbean Island States is modelled closely after the 2006 Regional Strategy for the Environmentally Sound Management of Used Lead Acid Batteries in Central America, Colombia, Venezuela and the Caribbean Island States1. This decision was adopted for the following reasons:

1. to utilize a previously accepted and familiar regional strategy approach that was, in part, tailored for Caribbean Island States2;

2. to demonstrate the flexibility and transferability of this model regional strategy for application to the environmentally sound management of other product-focused waste streams, including used oils;

3. to benefit from consistencies regarding the design and implementation of multiple product-focused regional strategies for the Caribbean Island States that share common strategic elements; and

4. to support and facilitate the delivery of regional and national integrated waste management policies, programs and initiatives in the Caribbean.

The Regional Strategy also incorporates information and strategic elements from additional strategy documentation, specifically: the Organization of Eastern Caribbean States (OECS) Strategy on the

Management of Used Oils (November 2002); the International Maritime Organization (IMO)3 Comprehensive Manual on

Port Reception Facilities (printed in 1995 and revised in 1999); the IMO Regional Waste Management Strategy for Port Reception Facilities in

the Wider Caribbean (May 1997); and the IMO Wider Caribbean Initiative on Ship-generated Waste (WCISW)

Report No. 4: Strategy and Action Plan for Source Reduction Recycling and Recovery of Ship-generated Waste (1996)

1 The regional strategy for used lead acid batteries was also funded under the Strategic Plan for the Implementation of the Basel Convention to 2010, and is being carried out by the Basel Convention Regional Centres in El Salvador and in Trinidad and Tobago, and the Secretariat of the Basel Convention under the UNEP. 2 The regional strategy for used lead acid batteries (ULAB) was approved by both the Executive and Regional ULAB Steering Committees at the Regional Consultations Meeting on the ESM of ULAB for Central America, Columbia, Venezuela and the Caribbean Island States held during 27-28 September 2006 in Chaguaramas, Trinidad and Tobago. 3 The IMO is the international organization that adopts shipping rules and standards in matters concerning maritime safety and security, efficiency of navigation, and the prevention and control of marine pollution from vessels.

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EXECUTIVE SUMMARY Used oils are defined as petroleum or synthetic oils that have been previously used for lubricating or other purposes and no longer meet the requirements of these applications. Since petroleum oil is a non-renewable resource that is in high global demand, its collection after use for environmentally sound resource recovery (i.e. re-refining, re-processing, high temperature burning as fuel) is recommended wherever it is found to be both economically and technically feasible to do so. Resource recovery strategies for used oils are also often used to minimize the need for country revenue expenditures on the importation of virgin oil. However, if managed improperly used oils may pose a threat to human health and the environment4. In the Group of Latin America and Caribbean (GRULAC) there are cases in which used oils have not been managed in an environmentally sound manner, which has led to a number of adverse impacts, including water, land and air pollution. Consequently the mismanagement of used oils may have long-term implications, not only for a country’s environmental health, but also for its economic and social growth and development. Within the GRULAC, a number of countries, particularly the Caribbean Small Island Developing States (SIDS), have resource constraints and challenges associated with the environmentally sound management (ESM) of used oils. In this regard, some Caribbean Basel Party States of the GRULAC agreed to develop a Regional Strategy for the Environmentally Sound Management of Used Oils in the Caribbean Island States. This Strategy was prepared under the Strategic Plan for the Implementation of the Basel Convention to 2010 to assist Party countries in planning for and adopting policies, programs and measures that support an integrated, coordinated and life cycle approach for the ESM of used oils in the region. The Strategy recognizes concepts and approaches such as the “polluter pays” principle5, extended producer responsibility6, product stewardship and environmental management systems7 as important elements in support of the ESM of used oils. The implementation of the Regional Strategy will, inter alia, build upon the successes achieved by the thirteen pilot countries (namely, Antigua and Barbuda, Bahamas, Barbados, Belize, Cuba, Dominica, Dominican Republic, Guyana, Jamaica, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, and Trinidad and Tobago) under Phase I of the regional initiative for used oils, which involved information gathering and needs assessment. Implementation of the Regional Strategy is however meant to be inclusive, and as such, will solicit the cooperation and active participation of all Basel Party States in the Wider Caribbean Region. Doing so will assist regional states in meeting obligations under various international conventions, specifically the Basel8 and the MARPOL9 Conventions, and enable the Wider Caribbean Region to be designated and implemented as a “special area” under

4 Many of the constituents found in used oils are also internationally recognized as hazardous and/or toxic substances. 5 The “polluter pays” principle is identified under principle 16 of the Rio Declaration on Environment and Development (Rio de Janeiro, 3-14 June 1992) 6 Organization for Economic Cooperation and Development’s Extended Producer Responsibility: Guidance Manual for Governments (2001) 7 ISO 14004 documentation provides general guidance on environmental management systems. 8 1989 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal 9 International Convention for the Prevention of Pollution from Ships (MARPOL Convention 73/78)

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Annex I of the MARPOL Convention which pertains to the prevention of pollution by oil10,11. The Regional Strategy specifically addresses both regional and national needs that have been identified through regional consultation forums. It is based on the following nine strategic goals, each of which is accompanied by underlying objectives and timeframes (see Section 3.5 for details):

1. Secure commitment from relevant stakeholders to promote ESM for used oils in accordance with the Basel Convention and the Basel Technical Guidelines, and the MARPOL Convention and its related guidance.

2. Assess the degree to which the ESM of used oils are supported at the national level.

3. Ensure national laws and compliance programs are sufficient to ensure the ESM of used oils.

4. Implement national programs (in a regional context) to collect used oils for ESM.

5. Implement financial mechanisms to support the delivery and effectiveness of national collection and management programs for used oils.

6. Compel facilities and operations, for which existing approaches to managing used oils are considered to be inadequate and/or problematic, to adopt improvements for the ESM of used oils.

7. Raise public awareness concerning the need for and importance of the ESM of used oils.

8. Identify remediation sites where contamination from used oils has been observed.

9. Promote technical assistance, including capacity building and technology transfer, to enhance the ESM of used oils in the region.

The Strategy advocates that national collection and management programs for used oils are economically sustainable, and where necessary, supported by financial intervention options (e.g. advance recycling fees, service charges, taxes, deposit-refund). However, financial and technical assistance from development and donor agencies will be required to support national efforts to establish collection and management programs for used oils in some Caribbean Basel Party States of the GRULAC.

10 Countries which ratify or accede to the MARPOL Convention are obligated to meet the requirement of Annex I (and Annex II) which are mandatory under the Convention. 11 The designation and implementation of the Wider Caribbean Region as a “special area” under Annex I of the MARPOL Convention would place more stringent limits on the discharge of oil into the sea from the normal operation of ships.

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TABLE OF CONTENTS

ACKNOWLEDGEMENTS .............................................................................................................................................................. 2

PREAMBLE.................................................................................................................................................................................... 3

EXECUTIVE SUMMARY ................................................................................................................................................................ 4

1 BACKGROUND................................................................................................................................................................... 8

2 CURRENT SITUATION ..................................................................................................................................................... 11

2.1 AVAILABLE BASELINE INFORMATION ............................................................................................................. 11 2.2 ANALYSIS OF THE PERCEIVED PROBLEM ..................................................................................................... 18 2.3 IDENTIFICATION OF NEEDS.............................................................................................................................. 22 2.4 RATIONALE FOR A REGIONAL STRATEGY ..................................................................................................... 26

3 REGIONAL STRATEGY FOR THE ENVIRONMENTALLY SOUND MANAGEMENT OF USED OILS IN THE CARIBBEAN ISLAND STATES ....................................................................................................................................... 28

3.1 OPTIONS FOR THE ENVIRONMENTALLY SOUND MANAGEMENT OF USED OILS ..................................... 28 3.2 PRODUCT SCOPE .............................................................................................................................................. 34 3.3 MISSION STATEMENT........................................................................................................................................ 36 3.4 VISION STATEMENT........................................................................................................................................... 36 3.5 GOALS ................................................................................................................................................................. 36 3.6 ANALYSIS OF THE STAKEHOLDERS................................................................................................................ 41 3.7 AN OVERVIEW OF COMMON APPROACHES TO FINANCING THE ESM OF USED OILS ............................ 45

ADVANCE RECYCLING FEES (LEVIES)................................................................................................45 “ADDED VALUE SERVICE” ..................................................................................................................... 49 SERVICE CHARGES............................................................................................................................... 50 TAX-BASE FUNDED SCHEMES............................................................................................................. 50 DEPOSIT-REFUND SCHEMES............................................................................................................... 51 TAX EXEMPTIONS (SUBSIDIES) ........................................................................................................... 52

4 CONCLUSIONS & RECOMMENDATIONS ...................................................................................................................... 54

ANNEXES..................................................................................................................................................................................... 56

ANNEX A: COUNTRY PARTY STATUS FOR SELECTED INTERNATIONAL TREATIES IN THE WIDER CARIBBEAN REGION................................................................................................................................................................ 57

ANNEX B: GEOGRAPHIC LOCATION OF COUNTRIES IN THE REGION THAT COULD POTENTIALLY PARTICIPATE IN THE REGIONAL STRATEGY ................................................................................................. 60

ANNEX C: SUMMARIES OF BASELINE INFORMATION REPORTED BY PILOT COUNTRIES......................................... 61 ANNEX D: VESSEL MOVEMENTS IN THE WIDER CARIBBEAN REGION......................................................................... 71 ANNEX E: SECONDARY TREATMENT OPTIONS FOR OIL-WATER SEPARATION......................................................... 78 ANNEX E: LIST OF ABBREVIATIONS .................................................................................................................................. 80 ANNEX F: USEFUL SOURCES OF INFORMATION............................................................................................................. 81

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TABLE OF TABLES, FIGURES AND BOXES TABLES TABLE 2.1.1: POTENTIAL LAND-BASED AND WATER-BASED SOURCES OF USED OILS IN THE CARIBBEAN............... 11 TABLE 2.1.2: ESTIMATED QUANTITIES OF NEW LUBRICATING OIL USED AND USED LUBRICATING OIL

GENERATED BY LAND-BASED SOURCES CARIBBEAN PILOT COUNTRIES ................................................ 12 TABLE 2.1.3: SELECTED PORTS AND MARINAS IDENTIFIED IN THE CARIBBEAN REGION ............................................. 13 TABLE 2.1.4: ESTIMATED QUANTITIES OF OILY WASTES GENERATED BY SHIPS FREQUENTING PILOT

COUNTRIES (AS OF 1996/1997) ......................................................................................................................... 15 TABLE 2.1.5: IDENTIFIED CRUDE OIL REFINERIES IN THE WIDER CARIBBEAN REGION THAT COULD

POTENTIALLY REFINE VIRGIN CRUDE OILS THAT HAVE BEEN BLENDED WITH USED OILS ................... 16 TABLE 2.1.6: OTHER IDENTIFIED INFRASTRUCTURE IN THE CARIBBEAN PILOT COUNTRIES THAT MAY BE

USED AS AN END-USE FOR USED OILS........................................................................................................... 17 TABLE 2.2.1: COMPARISON OF HAZARDOUS CONSTITUENT LEVELS IN SELECT TYPES OF USED OILS .................... 19 TABLE 3.1.1: ACTIVITIES NOT RECOMMENDED AS ELIGIBLE END-USES OR FINAL DISPOSITION OPTIONS FOR

USED OILS UNDER THE REGIONAL STRATEGY ............................................................................................. 31 TABLE 3.6.1: EXISTING/POTENTIAL ROLES FOR REGIONAL STRATEGY STAKEHOLDERS............................................. 42 TABLE 3.6.2: COMPANIES IN PILOT COUNTRIES THAT COULD POTENTIALLY PARTICIPATE IN THE REGIONAL

SCHEME................................................................................................................................................................ 44 TABLE 3.7.1: ECONOMIC INSTRUMENTS AND INCENTIVES APPLICABLE TO USED OIL MANAGEMENT....................... 46 FIGURES FIGURE 2.1.1: SHIPPING CONTAINER MOVEMENTS IN THE WIDER CARIBBEAN REGION.............................................. 14 FIGURE 3.1.1: NATIONAL OPTIONS FOR MANAGING USED OILS UNDER THE UMBRELLA OF A REGIONAL

STRATEGY.......................................................................................................................................................... 29 FIGURE 3.1.2: ENVIRONMENTALLY SOUND MANAGEMENT OPTIONS FOR THE FINAL DISPOSITION OF

USED OILS ......................................................................................................................................................... 30 FIGURE 3.6.1: RELATIONSHIP OF STAKEHOLDERS CONTRIBUTING TO THE REGIONAL STRATEGY ........................... 41 BOXES BOX 2.2.1: GENERAL FACTS ABOUT USED OILS................................................................................................................................. 20 BOX 2.3.1: ESSENTIAL NEEDS FOR A REGIONAL STRATEGY......................................................................................................... 22 BOX 2.3.2: EXAMPLES OF IMPROVEMENTS TO SUPPORT THE ESM AT FACILITIES AND OPERATIONS ......................... 25 BOX 3.2.1: TYPES OF USED OILS FOR INCLUSION UNDER THE REGIONAL STRATEGY ....................................................... 35 BOX 3.2.2: TYPES OF USED OIL FILTERS SPECIFIED FOR INCLUSION UNDER THE REGIONAL STRATEGY.................. 35 ANNEX TABLES TABLE A1: COUNTRY PARTY STATUS TO THE BASEL CONVENTION IN THE CARIBBEAN............................................. 57 TABLE A2: COUNTRY PARTY STATUS IN THE CARIBBEAN TO THE MARPOL CONVENTION .......................................... 58 TABLE A3: COUNTRY PARTY STATUS TO THE CARTAGENA CONVENTION IN THE CARIBBEAN REGION.................... 59 TABLE C1: PILOT COUNTRY DATA ON THE GENERATION OF USED OILS......................................................................... 61 TABLE C2: PILOT COUNTRY DATA ON LAWS & POLICIES APPLICABLE TO USED OIL MANAGEMENT.......................... 63 TABLE C3: PILOT COUNTRY DATA ON EXISTING APPROACHES TO USED OIL MANAGEMENT ..................................... 65 TABLE C4: PILOT COUNTRY DATA ON PUBLIC AWARENESS AND EDUCATION REGARDING USED OILS.................... 68 TABLE C5: PILOT COUNTRY DATA ON ENVIRONMENT AND HEALTH ISSUES RELATED TO USED OILS ...................... 70 TABLE E1: DESCRIPTION OF SECONDARY TREATMENT OPTIONS FOR OIL-WATER SEPARATION.............................. 78 ANNEX FIGURES FIGURE D1: GENERAL CARGO AND MISCELLANEOUS TRAFFIC IN THE WIDER CARIBBEAN REGION (1996 DATA) ... 72 FIGURE D2: PASSENGER VESSEL ROUTES IN THE WIDER CARIBBEAN REGION (1996 DATA)...................................... 74 FIGURE D3: CRUDE OIL TRAFFIC IN THE WIDER CARIBBEAN REGION (1996 DATA) ....................................................... 76

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1 BACKGROUND Used oils are petroleum or synthetic oils that have been previously used for lubricating or other purposes and no longer meet the requirements of these applications due to the presence of contaminants or impurities, or the loss of original properties. Wherever possible, every effort should be made to encourage the resource recovery (i.e. re-refining, re-processing, high temperature burning as fuel) of used oils, particularly since virgin petroleum oil is a non-renewable fossil fuel resource that is in high global demand. However, if managed improperly, used oils may pose a threat to human health and the environment. In fact, the improper disposal of used oils was cited as a serious problem in the Caribbean by regional states at the Regional Symposium on the Prevention of Degradation of the Quality of Inland Waster Systems and of the Marine Environment from the Adverse Effects of the Generation of Hazardous Wastes12, which was hosted by the Basel Convention Regional Centre for the Caribbean (BCRC-CARIBBEAN13) in December 1999 in Port of Spain, Trinidad. Used oils are classified as a hazardous waste under the 1989 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (Basel Convention) and have been identified as a priority for Environmentally Sound Management (ESM) in the Caribbean. To provide guidance on the ESM of used oils, Party countries14 to the Convention adopted the Basel Technical Guidelines on Waste Oils from Petroleum Origins and Sources (Y8) and Basel Technical Guidelines on Used Oil Re-refining or Other Reuses of Previously Used Oil (R9). Many are also Party countries to the 1973/78 International Convention for the Prevention of Pollution from Ships (MARPOL Convention)15 and the 1983 Cartagena Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Region (Cartagena Convention)16, each of which also contain provisions that support the ESM of used oils. Although there are good examples of compliance with national laws and international conventions applicable to used oils in the Caribbean, implementation and enforcement of existing requirements for the ESM of used oils throughout the whole region is still a matter of concern. The Ministerial Declaration on Environmentally Sound Management of Hazardous Wastes was adopted by the 5th Conference of the Parties (COP 5) to the Basel Convention in December 1999. The Ministerial Declaration called for enhanced partnerships between the public and private sector to improve the manner in which hazardous wastes and recyclables are managed in developing countries, thereby minimizing the potential risks to human health and the environment posed by these substances. To begin implementing the Ministerial Declaration, a first list of technical assistance projects was approved for funding at the 16th session of the Technical Group of the Basel Convention, held in Geneva, Switzerland, during April 2000. This list included the “Sub-regional project for building capacity on the

12 Small Island Developing States (SIDS) in the region first adopted used oils as a priority issue under the 1996 Programme of Action for the Caribbean, at the Regional Seminar on the Environmentally Sound Management of Hazardous Wastes held during 1-4 October 1996 in Castries, St. Lucia. 13 The BCRC-CARIBBEAN was then operated by the Caribbean Research Institute (CARIRI). 14 The term Party refers to a country government that has agreed to adopt an international convention by means of accession, acceptance, approval, formal confirmation, ratification or succession. 15 The MARPOL Convention is the most relevant international instrument for the reduction and prevention of pollution by wastes generated by the normal operation of ships. 16 The Cartagena Convention represents one of the main achievements of the Caribbean Environmental Program (CEP) in the area of marine pollution.

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Environmentally Sound Management of Used Oils in the Caribbean.” Thirteen Party countries to the Basel Convention in the region were selected to pilot this project, namely Antigua and Barbuda, Bahamas, Barbados, Belize, Cuba, Dominica, Dominican Republic, Guyana, Jamaica, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, and Trinidad and Tobago. A Regional Workshop on the Assessment of the Environmentally Sound Management of Used Oils in the Caribbean was held during 15 - 17 June 2004 in Port-of-Spain, Trinidad and Tobago to launch Phase I of the sub-regional project, which focused on gathering information and identifying problems linked to the generation, collection, storage, treatment, recycling and final disposal of used oils in the pilot countries. A follow-up workshop was held in St. Anns, Trinidad and Tobago during 21 - 22 March 2006 to share key observations from the pilot countries with other interested countries and relevant stakeholders in the region, and to commence Phase II activities under the sub-regional project, which involved the preparation of a Regional Strategy for the Environmentally Sound Management of Used Oils in the Caribbean. Regional technical assistance projects in support of the ESM of used oils have also taken place outside the auspices of the Basel Convention. Two noteworthy examples include:

1. the 1996-2003 Solid and Ship Generated Waste Management Project17 which was carried out by the Organization of Eastern Caribbean States (OECS), which led to, among other things, a Regional Strategy of OECS-member States in November 2002; and

2. the 1994-1998 Wider Caribbean Initiative for Ship-generated Waste (WCISW)18 which was implemented by the International Maritime Organization (IMO) to provide guidance to maritime authorities, government officials and private sector interests in designing and implementing national and regional approaches to assist port reception facilities meet provisions under the MARPOL Convention.

The information and strategic outcomes from each of the above initiatives was reviewed and incorporated in the Regional Strategy found here within. The Strategy was presented for discussion at the <regional consultation meeting to be determined> and subsequently revised and finalized, taking into account country and other stakeholder input. The Region, as defined by the Caribbean Island States, consists of both Party and non-Party countries to the Basel Convention. Implementation of the Regional Strategy could be further enhanced by the inclusion of non-Party countries in the region through the execution of bi-lateral, multi-lateral and/or regional agreements pursuant to Article 11 of the Basel Convention19. The Party status and geographic 17 The Solid and Ship Generated Waste Management Project was funded by the International Bank for Reconstruction and Development (IBRD), the Caribbean Development Bank (CDB), the Global Environmental Facility fund (GEF) and the Governments of the OECS participating countries. The project received $50.5 million USD over its 7-year period of duration. 18 The WCISW was funded by the Global Environmental Facility (GEF) through the World Bank. The project received $5.5 million USD over its 4-year period of duration. 19 Article 11 of the Basel Convention states that “… Parties may enter into bilateral, multilateral, or regional agreements or arrangements regarding transboundary movement of hazardous wastes or other wastes with Parties or non-Parties provided that such agreements or arrangements do not derogate from the environmentally sound management of hazardous wastes and other wastes as required by this Convention.”

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locations of all countries in the region that could theoretically participate in the implementation of the Regional Strategy are identified in Annexes A and B respectively.

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2 CURRENT SITUATION 2.1 AVAILABLE BASELINE INFORMATION Phase I of the regional initiative involved gathering information and assessing the ESM of used oils in each of the thirteen pilot countries that are Parties to both the Basel and MARPOL Conventions. Other Party countries in the region also participated throughout various stages of the regional initiative for used oils. The availability and detail of baseline information acquired by the pilot countries varied on a case-by-case basis. Country information pertaining to the generation, laws and policy, current management approaches, public awareness and education, and human health and environmental issues is summarized in Tables C-1 to C-5 of Annex C. There are many types and applications of petroleum and synthetic oil products. Generally, virgin oil products that are not consumed during use (e.g. engine oils, gear oils, hydraulic oils, insulating oils, etc.) can be collected as used oils for ESM20. Potential sources of used oils identified in the Caribbean are identified in Table 2.1.1. Table 2.1.1: Potential Land-based and Water-based Sources of Used Oils in the Caribbean

Vehicles and Machinery: cars, trucks and motorcycles heavy trucks and buses small engine equipment (e.g. lawn mowers, outboard motors) other vehicles and machines from operations listed below

Commercial Operations:

vehicle repair and servicing stations automotive dealerships airports and railways hotel and tourism trade fishery and farming operations (e.g. citrus, banana, sugar, etc.) telecommunications refrigeration and air conditioning repair shops

Industrial Operations:

electricity generating plants and transformer sub-stations oil refineries and processors construction and general trades

Land-based Sources

mining and metal operations Port Reception Facilities:

ports and terminals floating barges marinas, harbours, anchorages, and boatyards

Ships and Small Watercraft:

oil tankers and cargo vessels cruise ships commercial fishing vessels

Water-based Sources

recreational watercraft

The quality and volume of used oils produced by countries are important parameters in recommending a strategy, as resource recovery options may become inefficient or 20 It should be noted however that some petroleum and synthetic oils are consumed in use and therefore unavailable for collection. For example, some industry experts estimate that the amount of heavy duty engine oil consumed in trucking (via combustion or leakage) is 16.8%, and that the amount of motor oil consumed in use by passenger cars is estimated to be 5.3% (for year 2000 and newer vehicles) and 9.7% (for year 1999 and older vehicles). Engine oils are also consumed in equipment powered by 2-cycle motors which operate using a gasoline-oil mixture.

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ineffective in cases where there is insufficient feedstock of used oils for processing or the contaminant levels found in used oils exceed equipment design specifications. The annual quantities of virgin oil used and used oils generated by land-based sources in each of the pilot countries are summarized in Table 2.1.2. As indicated, country quantities of used oils generated per annum range between 250,000 - 5,000,000 litres (accounting for 58 - 76% of the quantity of lubricating oil used domestically) throughout the region. These quantities are significant considering that most countries do not have formal collection programs in place to ensure the ESM of used oils. Table 2.1.2: Estimated Quantities of New Lubricating Oil Used and Used Lubricating Oil Generated by Land-based Sources Caribbean Pilot Countries21

Pilot Country

Year of Statistic

Lubricating Oil Used Yearly

Estimated Used Oils Generated Yearly

(m3) (m3) (as % consumed)

1. Antigua & Barbuda 1999 426 320 75% 2. Bahamas N/A N/A N/A N/A 3. Barbados 2003 4,000 2,400 60% 4. Belize N/A N/A N/A N/A 5. Cuba N/A N/A N/A N/A 6. Dominica 2001 615 460 75% 7. Dominican Republic N/A N/A N/A N/A 8. Guyana N/A N/A N/A N/A 9. Jamaica 2002 8,600 5,000 58% 10. St. Kitts & Nevis 2001 330 250 76% 11. St. Lucia 2000 548 410 75% 12. St. Vincent & the

Grenadines 2001 794 600 76%

13. Trinidad & Tobago22 2002 801 516 64% N/A = information was not available 1 m3 = 1,000 litres = ~ 220 imperial gallons

The economy of countries in the Wider Caribbean Region is highly dependent upon maritime transportation. The region consists of important shipping routes for a wide variety of goods and commodities, and also represents a world leading destination for cruise ships, yachts and other recreational watercraft. Commercial and sport fishing is also widespread throughout the region. As a result, ship-generated oily wastes and port reception facility requirements for these wastes are important aspects that need to be addressed to ensure the ESM of used oils. Selected ports identified for each of the Caribbean pilot countries are identified in Table 2.1.3, while Figure 2.1.1 illustrates the scale of shipping container traffic in the Wider Caribbean Region. Additional figures illustrating vessel movements for general cargo, passengers and crude oil can be found in Figures D1, D2 and D3 of Annex D. Table 2.1.4 identifies the estimated quantities of oily wastes generated by ships frequenting pilot countries. Although this information is somewhat dated now, it does provide a useful measure of each country’s capacity needs to manage ship-generated oily wastes, which ranged between 252 - 4,472 metric tonnes per year. In all likelihood, an even greater requirement would exist today, nearly a decade later, due to a greater number of vessel movements by oil tankers, cargo ships, cruise ships, fishing boats and/or recreational watercraft in the region. This is significant 21 Based on information presented at the 2004 and 2006 Regional Workshops on the Assessment of the Environmentally Sound Management of Used Oils in the Caribbean held in Trinidad and Tobago. 22 Values reported for Trinidad and Tobago appear to be low given that this country is more industrialized and has a higher vehicle population than other Caribbean countries.

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considering that many port reception facilities in the region lack sufficient infrastructure to collect ship-generated wastes, including oily wastes, from ships and watercraft that call upon these ports23. Table 2.1.3: Selected Ports and Marinas Identified in the Caribbean Region

Country Location

1. Antigua & Barbuda

Codrington* Crabbs Marina* English Harbour* Fairmouth*

Heritage Quay Jolly Harbour* Saint John's (Antigua)

2. Bahamas Clifton Pier Freeport Bah, Borco Terminal

Freeport, South Riding Point Nassau

3. Barbados Bridgetown

4. Belize Belize City

5. Cuba

Aqua* Cardenas Carupano Cayo Largo del Sur* Chapelin* Cienfuegos Faro Luna* Guayabal Havana Hemingway*

Hotel Colony* Mariel Matanzas Moa Nueva Gerona Nuevitas Puerto Sol* Punta Gorda* Santa Lucia* Santiago de Cuba

6. Dominica Portsmouth Roseau

7. Dominican Republic Boca Chica La Romana Puerto Plata

Rio Haina San Pedro de Macorís Santo Domingo

8. Guyana Georgetown Linden

New Amsterdam Springlands

9. Jamaica

Huntress Marina* Kingston Montego Bay Montego Bay Yacht Club* Morgan’s Harbour Hotel* Ocho Rios Navy Island Hotel* Port Antonio

Port Antonio Yacht Club* Port Esquivel Port Kaiser Port Rhoades Rocky Point Royal Jamaica Yacht Club* Salt River Savanna La Mar

10. Saint Kitts & Nevis Basseterre

11. Saint Lucia

Cul-de-Sac Margot Bay* Pigeon Island* Port Castries

Rodney Bay* Soufriere* Vieux-Fort

12. Saint Vincent & the Grenadines Kingstown

13. Trinidad & Tobago

Chaguaramas Cronstadt Island Galeota Point Industrial Marine Services* Island Property Owners

Association* Peakes Yachting Services* Point Fortin Point Lisas

Pointe-a-Pierre Pointe-a-Pierre Yacht Club* Port-of-Spain Power Boats Mutual Facilities* San Fernando Yacht Club* Trinidad and Tobago Yachting

Association* Trinidad and Tobago Yacht

Club* * = Marina

23 It should be noted however, that the increased use of oil tankers with segregated ballast tanks is expected to have considerably reduced the need for port reception facilities for dirty ballast water.

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Figure 2.1.1: Shipping Container Movements in the Wider Caribbean Region24

24 Based on information presented during the 2006 Regional Workshop on the Assessment of the Environmentally Sound Management of Used Oils in the Caribbean held in Trinidad and Tobago.

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Table 2.1.4: Estimated Quantities of Oily Wastes Generated by Ships Frequenting Pilot Countries (as of 1996/1997)25

Small Vessels26 (i.e. less than 9,264 Dead Weight Tonnes)

Large Vessels27 (i.e. more than 9,264 Dead Weight Tonnes)

# of Voyages

Average Voyage

Oily Bilge

Oily Sludge

# of Voyages

Average Voyage

Oily Bilge

Oily Sludge

Total Oily Waste

Country

(/year) (days) (tonnes/ year)

(tonnes/ year) (/year) (days) (tonnes/

year) (tonnes/

year) (tonnes/

year) Antigua & Barbuda 1292 1.185 119 396 58 2.575 24 80 619

Bahamas N/A N/A N/A N/A N/A N/A N/A N/A N/A

Barbados N/A N/A N/A N/A N/A N/A N/A N/A N/A

Belize 316 3.325 81 272 48 4.715 36 122 511

Cuba 1821 2.335 330 1,099 1125 3.725 676 2,253 4,357

Dominica 2405 0.825 154 513 57 2.215 20 68 755

Dominican Republic 2136 2.195 364 1,212 1030 3.585 595 1,985 4,156

Guyana 1734 2.055 276 921 86 3.445 48 159 1,405

Jamaica 1274 1.215 120 400 967 2.605 406 1,354 2,280

Saint Kitts & Nevis 971 0.635 48 159 32 2.025 10 35 252

Saint Lucia 1253 1.905 185 617 238 3.295 126 422 1,350

Saint Vincent & the Grenadines 1017 1.435 113 377 110 2.825 50 167 708

Trinidad & Tobago 1892 2.975 437 1,455 846 4.365 595 1,985 4,472

Total Oily Waste (tonnes/year) - - 2,227* 7,421* - - 2,588* 8,630* 20,866*

N/A = information was not available * totals do not include estimated quantities for the Bahamas and Barbados Identified facilities in the Wider Caribbean Region that could potentially be used to refine virgin crude oils that have been blended with used oils are presented in Table 2.1.5. It is uncertain whether any of these refineries currently refine blended oils however, and it is anticipated that the technical and economic feasibility of refining virgin crude oils that have been blended with used oils will need to be examined on a case-by-case basis. It should be noted however, that only small volumes of used oils can be processed as blends in crude oil refineries, and that refining is not typically identified as a viable end-use option for used oils that have a high water or solid content (e.g. oily slops or tank washings and oily sludges). At this time no re-refineries for used oils have been identified in the Caribbean region28.

25 This information was extracted from the International Maritime Organization’s May 1997 Regional Waste Management Strategy for Port Reception Facilities in the Wider Caribbean. It should be noted however that figures for oily bilge and oily sludge waste, as reported by the International Maritime Organization’s Guide to Ports and Marinas Requiring Waste Reception Facilities (WCISW Report No. 3), were found to be slightly different. 26 The oily bilge rate and oily sludge rate for small ships was averaged to be 0.07756 tonnes/day/vessel and 0.2585 tonnes/day/vessel respectively. 27 The oily bilge rate and oily sludge rate for large ships was averaged to be 0.1612 tonnes/day/vessel and 0.5376 tonnes/day/vessel respectively. 28 Two used oils re-refinery operations have been identified in the USA, namely Evergreen Oil (in California) and Safety-Kleen (in Illinois). However it remains questionable whether these facilities represent economically viable end-use options for used oils generated in the Caribbean.

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Table 2.1.5: Identified Crude Oil Refineries in the Wider Caribbean Region that Could Potentially Refine Virgin Crude Oils that Have Been Blended with Used Oils

Country Refinery Operator Refining

Capacity29

(barrels per day) CARIBBEAN REGION

Aruba Aruba Refinery Valero 275,000 Nico Lopez Refinery Cupet 122,000 Hermanos Diaz Refinery Cupet 102,500 Cuba Cienfuegos Refinery Cupet 76,000

Netherlands Antilles Refineria Isla Refinery PDVSA 320,000 Dominican Republic Haina Refinery REFIDOMSA 33,000 Trinidad & Tobago Pointe-à-Pierre Refinery Petrotrin 165,000 US Virgin Islands St Croix Refinery PDVSA/Amerada Hess 494,000

NEIGHBOURING COUNTRIES Barrancabaermeja-Santander Refinery Ecopetrol 242,000 Cartagena Refinery Ecopetrol 79,000 Apiay Refinery Ecopetrol 2,250 Orito Refinery Ecopetrol 1,800

Colombia

Tibu Refinery Ecopetrol 1,800 Costa Rica Puerto Limón Refinery Recope 25,000 El Salvador Refineria Petrolera de Acajutla SA de CV Refinery RASA / ExxonMobil 22,000 Nicaragua Cuesta del Plomo-Managua Refinery ExxonMobil 20,900 Surinam Paramaribo Refinery Staatsolie 7,000

Centro de Refinación de Paraguaná (CRP) Refineries PDVSA 956,000 Amuay Refinery (CRP) (635,000) Cardón Refinery (CRP) (305,000) Bajo Grande Refinery (CRP) (16,000)

Puerto La Cruz Refinery PDVSA 200,000 El Palito Refinery PDVSA 130,000

Venezuela

San Roque Refinery PDVSA 5,200 1 barrel = 55 litres = ~ 12 imperial gallons Other identified facilities in the Caribbean pilot countries that are currently being applied or could be applied as end-use options for used oils are listed in Table 2.1.6. In general, these facilities involve the re-processing, high temperature burning (as fuel), or destruction of used oils. Centralized storage facilities for used oils have also been identified for countries that lack domestic end-use or final disposition options for used oils. Where available, the capacity for each end-use option has also been identified. Although not developing countries, it may also interesting to note that some of the islands in the Wider Caribbean Region are affiliated with, or are provinces of, countries of the European Union (EU), and therefore bound by the EU Waste Oil Directive (i.e. Directive 75/439/EEC as amended) that requires EU Member States to ensure that waste oils are collected and managed in an environmentally sound manner (by processing, destruction, storage, or tipping above or under ground), with priority to the processing of waste oils by regeneration (i.e. by re-refining/re-processing)30. Examples include France (e.g. St. Martin, St. Barthélemy, Guadeloupe, and Martinique); the Netherlands (e.g. Aruba, Curaçao, Bonaire); and the United Kingdom (e.g. Cayman Islands, Anguilla, Montserrat, and the British Virgin Islands).

29 These figures are based on capacities as reported by Wikipedia at http://en.wikipedia.org/wiki/List_of_oil_refineries. 30 The European Commission has proposed to repeal the EU Waste Oil Directive under ongoing deliberations related to revising the Waste Framework Directive (Directive 75/442/EEC). The Commission has also indicated that the priority placed on the regeneration of waste oils over other types of recovery options (e.g. burning waste oils as a fuel) is no longer justified.

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Table 2.1.6: Other Identified Infrastructure in the Caribbean Pilot Countries that may be Used as an End-use for Used Oils

Country Facility End-Use Type Demand/Capacity for Used Oil

Antigua & Barbuda West Indies Oil Company (WIOC)* Destruction (Biopile) ~ 400,000 imperial gallons per year

Bahamas N/A N/A N/A Barbados National Terminal Company Limited (BNTCL)*

Resource Recovery (Blending for Refining) N/A

Barbados Arawak Cement Company Limited (ACCL)** Resource Recovery (Kiln Fuel) N/A

Belize Electricity Limited* Collection (Storage Tank) N/A Belize The Shell Terminal* Collection (Storage Tank) N/A Manel Cement Factory** Resource Recovery (Kiln Fuel) 5,500 tonnes/year Siguaney Cement Factory** Resource Recovery (Kiln Fuel) 3,500 tonnes/year Cuba Santiago de Cuba Cement Factory** Resource Recovery (Kiln Fuel) 4,900 tonnes/year

Dominica N/A N/A N/A Dominican Republic N/A N/A N/A Guyana N/A N/A N/A Jamaica Caribbean Cement Company Limited* Resource Recovery (Kiln Fuel) N/A

Saint Kitts & Nevis Conaree Landfill facility* Collection (Storage Tank) 50,000 imperial gallons

St. Lucia Distillers Limited* Resource Recovery (Boiler Fuel) ~143,520 imperial gallons/year Saint Lucia

St. Lucia Linen Services Limited* Resource Recovery (Boiler Fuel) ~109,200 imperial gallons/year

Saint Vincent & the Grenadines N/A N/A N/A

Oil Mop Services31* Resource Recovery (Re-processing) ~72,000 barrels/year

Earth Company Limited* Resource Recovery (Re-processing) N/A La Brea Industrial Estate* Destruction (Biopile) N/A Trinidad Cement Limited32** Resource Recovery (Kiln Fuel) N/A

Trinidad & Tobago

Tobago Landfill* Collection (Storage Tank) 15,000 imperial gallons

N/A = information was not available * = currently processing used oils 1 m3 = 1,000 litres = ~ 220 imperial gallons ** = could potentially process used oils 1 barrel = 55 litres = ~ 12 imperial gallons

31 Oil Mop Services also operates another smaller facility in St. Martin. 32 Trinidad Cement Limited currently uses natural gas as a kiln fuel.

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2.2 ANALYSIS OF THE PERCEIVED PROBLEM The composition of petroleum oil before and after use may vary depending on the type of oil and its application. Motor oils used in diesel and gas-powered engines for example, generally consist of a base lubricating oil consisting of a complex mixture of hydrocarbons (80 to 90% by volume) and performance-enhancing additives (10 to 20% by volume). Oils are generally altered during use due to the breakdown of the additives, contamination from the by-products of combustion, the addition of metals from engine wear, and/or exposure to other substances, including dirt and water. During collection, used oils are also frequently mixed with other types of used oils (including motor oils, industrial lubricating oils, hydraulic oils, metal working and cutting oils, heat transfer oils, oil storage tank bottoms, and oil/water mixtures). Poor segregation practices during the collection of used oils may also introduce other contaminants to the mixture such as, chlorinated solvents and other organic solvents (e.g. glycols, polychlorinated biphenyls, polychlorinated terphenyls). For this reason, the composition of used oils are variable and difficult to characterize. Used oils are classified as hazardous wastes under Annex I (Y8 - waste mineral oils unfit for their originally intended use; Y9 - waste oils/water, hydrocarbons/water mixtures, emulsions) of the Basel Convention, in part due to the presence of constituents that are individually designated as hazardous wastes under the Convention and assessed to be toxic to human health and/or the environment by some countries within the global arena. Table 2.2.1 lists the types and concentrations of several substances found in select types of used oils. If released into the environment, used oils (and their constituents) can contaminate air, water and soil, with considerable potential to harm to terrestrial and marine life. Air pollution is generally caused by the incomplete combustion of used oils (commonplace where open burning or low temperature burning is adopted), the use of equipment that is not specifically designed and approved for the combustion of used oils, and the burning of used oils that contain high levels of contaminants (e.g. heavy metals). Water and soil pollution is generally caused by oil spills, and the crude dumping or discharge of untreated or improperly treated oily waste into the environment. This may lead to long-term contamination requiring remediation that is often very costly to undertake. Groundwater used for drinking may also be at a higher risk for contamination from used oils in areas associated with a high water table. Used oils are pervasive in the environment because they are slow to degrade and tend to spread quickly over large areas. Oily films that are created may prevent the replenishment of dissolved oxygen (eutrophication), block sunlight, and impair photosynthetic processes, adversely affecting the terrestrial and/or aquatic life that lives in this media. Used oils are also known to adhere to all types of surfaces, including beaches, ships, and waterfowl. Lastly, many of the heavy metal constituents commonly found in used oils are known to bioaccumulate in the tissue of living organisms when they enter the food chain. Some additional facts about used oil are presented in Box 2.2.1.

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Table 2.2.1: Comparison of Hazardous Constituent Levels in Selected Types of Used Oils33

Parameter34 Gasoline Engine Oils (ppm)

Diesel Engine Oils (ppm)

Hydraulic Oils (ppm)

Cutting/Machine Oils (ppm)

Range Median (n) Range Median (n) Range Median (n) Range Median (n) Metals

Arsenic <0.4 - 17 <5 (44) <5 - 5.9 <5 (5) N/D N/D (8) N/D N/D (12) Barium 2 - 3,906 87 (138) 0.78 - 19 4.1 (5) <0.5 - 56 3.1 (9) <0.5 - 330 23 (29) Cadmium 0 - 8.8 1.3 (86) <0.5 - 1.4 0.88 (5) <0.5 - 4 0.5 (10) 0 - 21 0.5 (39) Chromium 0.3 - 50 7.7 (123) 0.86 - 3.8 1.5 (5) <0.1 - 3 0.5 (10) 0 - 520 2 (39) Lead35 8.5 - 21,676 390 (87) <5 - 78 13 (5) <0.6 - 150 5 (10) <0.01 - 3,500 16 (40) Zinc 6 - 3,000 990 (142) 4.4 - 820 280 (5) <0.5 - 600 17 (10) 0.53 - 530 38 (41)

Chlorinated Solvents 1,1,1-Trichloroethane 445 4 (18) 200 - 200 200 (2) <2 - 62,000 4 (8) N/D N/D (12) Trichloroethylene 84 - 2,600 2,600 (1) <2 - 18 4 (8) <4.1 - 26,000 15 (14) Tetrachloroethylene 453 - 293 293 (1) <2 - 980 4 (8) <2.2 - 2,400 15 (13) Dichlorodifluoromethane N/M N/M N/M N/M N/M N/M N/M N/MTrichlorotrifluoroethane N/M N/M N/M N/M N/M N/M 100,000 - 300,000 10,000 (2)

Total Chlorine

N/M N/M N/M N/M 100 - 24,600 200 (8) 100 - 86,700 4,000 (14)

Other Organic Solvents Benzene 92 4 (18) 21 21 (1) <2 - 100 4 (8) N/D N/D (12) Toluene 1,374 - 1,960 1,960 (1) <2 - 6,300 9 (8) <7 - 5,700 15 (14) Xylenes 1,289 - 1,817 1,817 (1)

<2 - 700 7 (8) <7 - 1,100 70 (14)

Benzo(a)pyrene 11.7 - 1.3 - 1.7 1.5 (4) N/M N/M N/M N/MBenzo(a)anthracene N/M N/M N/M N/M N/M N/M N/M N/MNapthalene N/M N/M N/M N/M N/M N/M N/M N/MPCB N/M N/M N/M N/M N/D N/D (8) <5 - 38,000 5 (13)

(n) = number of samples analysed N/D = non-detect N/M = not measured

33 Source: Canadian Council of Ministers of the Environment (CCME) Code of Practice for Used oil management in Canada. CCME-TS/WM-TRE006E, August 1989. 34 Used oils may also contain polynuclear aromatic hydrocarbons (PAH) resulting from the by-products of incomplete combustion, glycols (e.g. antifreeze) resulting from poor segregation practices at garages, and polychlorinated terphenyls (PCT) which may be found in some types of transformer oils. 35 Due to the fact that this analysis is now somewhat dated, the reported concentrations of lead are considered to be higher than those found in used oils of today due to the predominance of unleaded fuels for motor vehicles in the international marketplace.

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In addition, a number of questionable end-uses for used oils have been identified in the Caribbean region that may lead to environmental degradation. Examples include the use of used oils as a larvicidal agent for mosquitoes, marking agent for sports fields, wood preservative to protect against termite infestation, herbicide for fence posts, pesticide for vermin, and parasite control treatment for livestock. In most cases, containers and filters containing residual amounts of virgin or used oil also undergo landfill disposal. Used oils should not be commingled with residential waste for landfill, because they pose a flammability hazard to workers that collect and dispose of garbage, and may leach from garbage trucks and landfills. Wherever possible, used oils should be treated as a non-renewable resource which is collected for resource recovery. However, resource recovery options may also pose a risk to the environment if improperly managed. For example, used oil re-refineries and re-processors, and end-users that burn used oils as a source of fuel generate process wastes36 and air emissions that also require ESM. Box 2.2.1: General Facts About Used Oils Used oils may contain toxic substances, including heavy metals, chlorinated solvents, and other organic solvents (see

Table 2.2.1). Traditional river use is still carried out to meet basic day-to-day needs such as bathing, cooking, washing and drinking in

some areas of the Caribbean. One litre of used oils may contaminate up to 1 million litres of freshwater – enough to supply 50 people with drinking

water for 1 year37. Films of oil on the surface of water prevent the replenishment of dissolved oxygen, impair photosynthetic processes,

and block sunlight. One part per million (ppm) of oil can be detected by odor and taste, and 35 ppm of oil can cause a visible slick38. One litre of used oils can form a 4,000 m2 slick on water39. Used oil concentrations of 50 - 100 ppm can disrupt sewage treatment processes40. An undrained oil filter can contain between 250 millilitres to 1 litre of used oil41. Recycling 1 ton of used oil filters recovers 1,700 pounds of steel and up to 60 gallons of used oil42. Only one-third of the energy required to refine crude oil into virgin base oil is needed to manufacture re-refined oil from

used oils43. One barrel (42 gallons) of crude oil is needed to manufacture 2½ quarts of lubricating oil, but only 1 gallon of recycled

oil is needed to manufacture an equal amount of re-refined lubricating oil44. Two gallons of recycled oil can generate enough electricity to run the average household for almost 24 hours45. The average price for a barrel of crude oil from Organization of Petroleum Exporting Countries (OPEC) was $55 USD

on November 3, 2006. The average acquisition cost for a barrel of crude oil was $60.71 USD for oil refiners in September 200646.

Many of the problems associated with used oils in the region stem from a notable lack of public awareness and education concerning the potential risks of improperly disposing of used oils and the importance of ESM. They are also linked to institutional weaknesses (e.g. inadequate regulations and enforcement coupled with shared, but poorly defined, organizational duties; lack of skills to identify, monitor and correct unsafe practices for managing used oils), and the lack or insufficient adoption

36 Process wastes may include distillation bottoms, filter cakes, acid tar, spent clay, centrifuge sludge, waste water, and/or ash. 37 South Carolina Department of Health and Environmental Control (SCDHEC). www.scdhec.gov. 38 Nebraska Cooperative Extension, “Handling Wastes: Used Oil and Antifreeze,” August 1994. www.ianr.unl.edu/pubs/wastemgt/nf196.htm. 39 Spent Oil Generation (SPORE). www.ics.trieste.it/xportal/XPRemediation/SPORE/Environmental.aspx. 40 U.S. Environmental Protection Agency, Solid Waste and Emergency Response (OS–305), EPA530-SW-89-039A, May 1989. 41 Alberta Used Oil Management Association. www.usedoilrecycling.com. 42 Minnesota Office of Environmental Assistance (MOEA). www.moea.state.mn.us/reduce/oil.cfm. 43 Müller Associates, Inc (1989). Waste Oil - Reclaiming Technology, Utilization and Disposal. Noyes Data Corporation, Park Ridge, New Jersey. 44 Alabama Department of Environmental Management (ADEM). February 2002. Household Waste Disposal. 45 American Petroleum Institute (API). www.recycleoil.org. 46 United States Department of Energy (DOE).

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of industry standards and best operating practices. However it is important to recognize that the problem is not identical throughout the region, since countries do not possess identical institutional or used oil management issues. A common issue for all countries is the lack of adequate collection facilities for both land-based sources and ship-generated used oils47. This short-coming may be of particular significance to small ships, small businesses (e.g. garages, farms), “do-it-yourself” mechanics and households that generate used oils but are often unable to keep it for long periods of time. In some cases, the associated cost of collection services may also act as a deterrent to pursue environmentally sound end-uses and final disposal options for used oil, especially in low income groups and/or informal sector facilities and operations48. The wide variety of sources (see Table 2.1.1) and types (see Table 3.2.1) of used oils will undoubtedly add an additional layer of complexity to national and regional solutions for the ESM of used oil, because in some cases certain streams of oil may need to be collected and managed separately due to their composition. Some countries may also be reluctant to expand collection networks for used oils (where they exist) due to the fact that they may not have sufficient (or any) domestic infrastructure in place to carry out resource recovery or final disposal of used oils. This raises an important point, specifically that the problems of used oils can not be resolved through collection alone. Instead they must be resolved by implementing environmentally sound collection and end-uses or final disposition options for used oils that are capable of handling the expected types and volumes of used oils generated. As a result, the importance of a regional approach is paramount for Caribbean countries in which environmentally sound end-uses or final disposition options for used oils are found to be lacking. To support ESM, it is important to ensure that national laws provide a suitable level of protection to human health and the environment from the risks posed by used oil, and that these laws are enforced in a coordinated and consistent fashion by competent authorities. For example, it has been noted that several Party countries in the region do not maintain notification and movement forms for used oils (and other hazardous wastes). This is evidenced by the lack of information and country data on used oils imports and exports and the lack of national reporting information concerning the transboundary movement of hazardous wastes which is made available to the Secretariat of the Basel Convention. These issues demonstrate that many Party countries in the region are currently operating in contravention to the Basel Convention. It has also been noted that, in some cases, government Ministries share administrative and enforcement duties under individual national laws. This can pose challenges in the effective and efficient delivery of laws (including inspection and monitoring), particularly if roles and responsibilities of authorities are not clearly

47 The IMO Guide to Ports and Marinas Requiring Waste Reception Facilities (WCISW Report No. 3) indicates that very few of the commercial ports, with the exception of oil loading terminals, have reception facilities for the management of ship-generated oily waste. 48 Formal sector businesses strive to ensure conformity with applicable national laws, policies and best management practices that pertain to their activities, and generally possess the government approvals, licenses, permits, and other requirements necessary for their operations. In contrast, informal sector businesses do not operate within a legal context, and consequently may pose greater risks to human health and the environment.

21

defined and if government Ministries do not coordinate efforts. Within a regional context, the national laws and administrative requirements from one country to the next lack consistencies and undergo irregular enforcement activities by government officials. This climate presents challenges with respect to facilitating international trade and assuring ESM for used oils. Lastly, Caribbean countries seem to lack incentives which are clearly needed to encourage the emergence of and consumer participation in environmentally sound collection and management programs for used oils, and to help drive infrastructure and process improvements in both informal and formal sectors. Some examples of financial intervention options applicable to used oil management are identified in Section 3.7. 2.3 IDENTIFICATION OF NEEDS It is important to ensure that oil is managed in a safe and environmentally sound manner throughout all stages of its life cycle, including its initial extraction, refinery and use, and collection, storage, transport, resource recovery (i.e. re-refining, re-processing, high temperature burning as a fuel) and/or final disposal (i.e. incineration, destruction, controlled storage) after use. The goals of the Regional Strategy (see Box 2.3.1) represent the essential needs that were identified throughout the course of the Phase I and Phase II activities of this regional initiative. The cooperation and coordination of participating Party countries is essential to ensure that each of these needs is effectively addressed from both a national and regional perspective. A brief description of each essential need follows. Box 2.3.1: Essential Needs for a Regional Strategy

1. Secure commitment from relevant stakeholders to promote ESM for used oils in accordance with

the Basel Convention and the Basel Technical Guidelines, and the MARPOL Convention and its related guidance.

2. Assess the degree to which the ESM of used oils are supported at the national level. 3. Ensure national laws and compliance programs are sufficient to ensure the ESM of used oils. 4. Implement national programs (in a regional context) to collect used oils for ESM. 5. Implement financial mechanisms to support the delivery and effectiveness of national collection

and management programs for used oils. 6. Compel facilities and operations, for which existing approaches to managing used oils are

considered to be inadequate and/or problematic, to adopt improvements for the ESM of used oils. 7. Raise public awareness concerning the need for and importance of the ESM of used oils. 8. Identify remediation sites where contamination from used oils has been observed. 9. Promote technical assistance, including capacity building and technology transfer, to enhance the

ESM of used oils in the region. There is a need to secure commitment from relevant stakeholders to promote ESM for used oils in accordance with the Basel Convention and the Basel Technical Guidelines, and the MARPOL Convention and its related guidance. It is therefore important to identify all the stakeholder organizations which will participate in the implementation of the Regional Strategy and to clarify their respective contributions, roles and responsibilities. Many of these organizations will be required to work together under the auspices of multi-stakeholder National and Regional Steering Committees for Managing Used Oils, which are designed to coordinate all aspects of

22

Strategy delivery, and to encourage country-specific policies, programs and measures for used oils that share regional consistencies. Establishing clear political support, at the national and regional levels, will also help to encourage industry engagement, the development of legislative instruments, industry standards, and economic instruments that may be necessary to ensure the ESM of used oils at both the national and regional levels. The Strategy may be submitted to relevant government ministries and/or Cabinet in the respective countries for endorsement. Regional political support can be garnered by communicating the Strategy to regional forums of heads of governments, such as meetings of the Health and Environment Ministers of the Americas and regional economic integration groups (e.g. the Caribbean Community or CARICOM). The need for political support is also important from the perspective that the region consists of both Party and non-Party countries to the Basel and the MARPOL Conventions. Although the potential inclusion of non-Party countries may present challenges, it may also drive program efficiencies by establishing larger economies of scale and it will undoubtedly contribute to a higher level of protection to the health and environment of the region. Additional information will be required to assess the degree to which the ESM of used oils is supported at the national level. For the most part, this will involve identifying facilities and operations that generate, collect, store, transport, treat, re-refine/re-process, burn (as fuel) and dispose of used oils. This includes examining the practices that they have in place for ESM, identifying their capacity for managing used oils, and estimating the quantity of used oils generated from all potential domestic sources. Although information from pilot countries presented at the 2004 and 2006 regional meetings do provide some of this baseline information already, in some cases certain data was either presented/calculated in an inconsistent fashion or missing altogether. Consequently, further refinements of existing baseline studies are necessary to ensure that a reliable source of information exists upon which to base country-specific and regional decisions. It will also be necessary to ensure that national laws and compliance programs are sufficient to ensure the ESM of used oils. Although in most cases these laws will not be specific to the management of used oils alone, they can and do provide a legal framework to help protect human health and the environment. For this reason it is important to identify and assess whether existing laws provide the level of protection that is deemed to be necessary, and to address any legislative gaps where they may exist. It may also be useful to consider introducing regulations that make either producers and first importers or retailers of non-consumable oil products responsible for designing and delivering collection and management programs for used oils49. Wherever possible, every attempt should be made to coordinate national legislative activities and to encourage consistencies in regulatory requirements throughout the region. Regulatory authorities should also receive the necessary training to ensure that existing national laws applicable to the management of used oils are being administered and enforced properly. In some countries, opportunities may also exist to adopt policies and regulations that support the collection of used oils for ESM. These may include, for example, prohibitions for the disposal of used oils to landfill, land, sewers, and water; prohibitions regarding the application of used oils for the

49 A variety of program designs are identified in Section 3.7 in the context of common approaches to financing ESM collection and management programs for used oils.

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purposes of dust suppression; restrictions regarding the burning of used oils as a source of fuel; and air emission limits regarding the combustion of used oils. Implementing national programs (in a regional context) to collect used oils for ESM is vital to ensure that used oils are returned to facilities and operations in the formal sector which conform to the principles of environmentally sound management. Doing so may also create a strong business case (economic driver) for upgrading facilities and operations (where necessary) to ensure eligibility for program participation as ESM-compliant end-uses and final disposition options for used oils. Such an undertaking will need to be supported by the development of regionally consistent ESM criteria and National Action Plans. These national programs will need to integrated regionally, because many countries in the region do not have sufficient (or any) capacity to re-refine/re-process, burn (as fuel) or dispose of used oils in an environmentally sound manner. Consequently, they must export used oils to those countries that do have sufficient capacity for ESM-compliant resource recovery, treatment, stabilization, or destruction of used oils. Also, it may be the case that some SIDS in the Caribbean do not generate sufficient quantities of used oils to make direct consignments with island or mainland countries in the Wider Caribbean Region an economically feasible option. As a result, there may a need to consider the possibility of establishing regional collection centres which bulk cargo into consignment-sized loads for export to countries which possess adequate processing capacity for used oils. However, to truly ensure the ESM of used oils throughout the region, these and other activities must take place within the spirit of international cooperation. It is also paramount to foresee the deployment of financial and economic mechanisms, as well as support measures, to facilitate the delivery and effectiveness of national collection and management programs for used oils. Incentives are needed in both informal and formal sectors to help drive facility and process improvements, and to promote, strengthen and ensure the sustainability of ESM for used oils. Examples include advance recycling fees, “added value service” schemes, service charges, tax-base funded schemes, deposit-refund schemes, and tax exemptions. A brief description of each is presented in Section 3.7. Throughout this process, it will be crucial to compel facilities and operations, for which existing approaches to managing used oils are considered to be inadequate and/or problematic, to adopt improvements for the ESM of used oils. This will involve identifying facilities and operations that fall into this category (i.e. from both informal and formal sectors), and enabling them to implement practical and economically feasible improvements to correct business activities that may pose a risk to human health and the environment. Box 2.3.2 illustrates some examples of the types of improvements that may be considered necessary depending on the type and scale of operation. It is presumed however, that many facilities and operations will not have the financial ability to integrate many of these improvements on their own, and that it will be necessary to examine how national policies, programmes and mechanisms, including financial intervention options and other support measures, can assist facilities and operations to this end.

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Given the fact that many individuals in developing countries rely on the income derived from informal sector activities (e.g. some road-side garages), it is important to identify and adopt solutions that are responsive to the needs of this community as well. In effect, measures must be able to phase out undesirable activities such the crude dumping and open burning of used oils, and focus on desirable activities such as collecting used oils for resource recovery. At the same time, it is equally important to prosecute the worst and most deliberate offenders to protect community health and the environment. Box 2.3.2: Examples of Facility & Operational Improvements to Support the ESM of Used Oils

government approvals, licenses, permits, and other operational requirements50

employee training:

- environmental awareness - occupational safety and health - emergency response - best management practices for used oils - other training that may pertain to the following bullets

formalized plans, procedures, and/or services - spill prevention and spill contingency plans - employee training plans - quality testing procedures for the collection and resource recovery of used oils - standard operating procedures for handling used oils - waste management plans and services for used oils and process wastes - industry standards best management practices for used oils

facility and/or equipment upgrades - personal protection equipment - storage tanks and containers - quality testing equipment - treatment systems - pollution prevention, control and abatement systems - spill containment devices - spill emergency response equipment

Many of the problems identified in Section 2.2 may be averted by simply raising the level of public awareness concerning the importance of managing used oils in an environmentally sound manner. Appropriately designed public awareness campaigns targeting susceptible communities (e.g. using television, radio, newspapers and other communication tools), will also help to generate public pressure to participate in collection and management programs for used oils, and for businesses, consumers and end-users to ensure the ESM of used oils that they may generate or manage. It is necessary to identify remediation sites where contamination from used oils has been observed using inexpensive techniques to allow for corrective actions to be taken to minimize continued exposure to water and soil that has been contaminated

50 These requirements help to ensure that facilities and operations are operating in the formal sector and conform with applicable national laws, policies and best management practices that pertain to their activities.

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by used oils51. This basically entails reporting sites that are suspected to be contaminated by used oils to government authorities that are directly responsible for assessing and remediating contaminated site issues. This activity, although limited to notifying the appropriate authorities for follow-up action, is important none-the-less from a health and environmental perspective. It should be noted however that the actual remediation of sites that have been contaminated by used oils and associated resources necessary to accomplish this undertaking are beyond the scope of this Regional Strategy. Lastly, technical assistance, including capacity building and technology transfer, is required to strengthen the region’s ability to manage used oils in an environmentally sound manner. Training is required for key public sector groups (particularly health officials, customs officials, the judiciary and other enforcement officers) to enhance the enforcement network at both the national and regional level. Training involving the remediation of sites that have been contaminated with used oils should also be accessed, using institutions that possess technical expertise in this area. Capacity building will also assist in minimizing the illegal traffic of hazardous wastes, including used oils, in the region by enhancing the level of awareness of and compliance with applicable legislation. Technical and financial resources are also required to improve existing and establish new infrastructure for the collection, storage, transport, treatment, resource recovery and final disposal of used oils in many countries. Also, increasing the region’s research and development capabilities will help to foster the development of clean technologies as well as environmentally friendly alternatives, where necessary. 2.4 RATIONALE FOR A REGIONAL STRATEGY The following were identified as rationale in support of the development of a regional strategy for the ESM of used oils, namely:

1. Used oils are identified as hazardous wastes under the Basel Convention, and consequently pose a serious risk to the human health and the environment if improperly managed.

2. Throughout the region, there are several examples in which used oils are not being managed in an environmentally sound manner.

3. Limited capacity to manage the quantities of used oils generated domestically exists within a majority of countries in the region, in particular access to environmentally sound collection, resource recovery and final disposal facilities and operations for used oils.

4. The discharge of oil (and chemicals, sewage and garbage) into the sea from the normal operation of ships is strictly limited under the MARPOL Convention.

5. Many Caribbean countries are requesting that the Wider Caribbean Region be designated and implemented as a “Special Area” under various Annexes of the MARPOL Convention, including Annex I regulations for the prevention of pollution by oil which would place more stringent limits on the discharge of oil into the sea from the normal operation of ships52,53.

51 At the 2004 Regional Workshop on the Assessment of the Environmentally Sound Management of Used Oils in the Caribbean, the remediation of oil contaminated sites was expressed as an issue by Trinidad and Tobago, Jamaica and Cuba. 52 For example, the designation and implementation of the Wider Caribbean Region as a special area under the MARPOL Convention would prohibit the discharge into the sea of oil or oily mixtures from any ship of 400 gross tonnage and above. In this situation, oil must be retained onboard until it can be discharged at a port reception facility. Implementation of the special

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6. Implementation of a regional strategy will help Caribbean countries to meet the requirements of the Basel and the MARPOL Conventions, and help to designate and implement the Wider Caribbean Region as a “Special Area” under Annex I of the MARPOL Convention.

7. It is critical to eliminate illegal traffic and compel the ESM of hazardous wastes in the region, specifically used oils.

8. Caribbean countries recognize that petroleum oil is a non-renewable resource that is in high global demand, and that used oils should be collected for end-uses that favour resource recovery wherever technically and economically feasible.

Consequently some Caribbean Basel Party states of the Group of Latin America and the Caribbean (GRULAC) have agreed to adopt a regional approach to support the ESM of used oils in the region. It is also important to note that, in addition to the Basel and the MARPOL Conventions, many countries of the region are Party to the Cartagena Convention for the Protection and Development of the Marine Environment in the Wider Caribbean (Cartagena Convention)54 that includes the Protocol Concerning Cooperation in Combating Oil Spills in the Wider Caribbean Region55, the Protocol on Specially Protected Areas and Wildlife56, and the Protocol on Marine Pollution from Land-Based Sources and Activities57 (see Annex A, Table A3). Implementing a regional solution that supports the ESM of used oils demonstrates an ongoing commitment of Party countries to each of these international agreements. On the other hand, long-term failure to address specific problems and needs pertaining to used oils on a regional basis could potentially raise international concerns regarding the scope and magnitude of used oil contamination in the region, and could adversely impact the tourism and fishing industries of countries the Wider Caribbean Region.

area designation can not take effect until governments of countries with coastlines that border the special area assure that adequate port reception facilities exist to effectively and efficiently manage ship-generated oily wastes in an environmentally sound manner. 53 Other Annexes of the MARPOL Convention pertain to the management of chemicals, sewage and garbage from ships. 54 The Cartagena Convention in part requires Parties to prevent, reduce and control pollution in the Convention area and to ensure sound environmental management, using for this purpose the best practicable means at their disposal and in accordance with their capabilities. 55 The Oil Spill Protocol establishes a mechanism to respond to discharges or threats of discharges (including oil and other hazardous or toxic substances) that could endanger the marine environment and coastal interests of the countries. 56 The SPAW Protocol aims to protect and preserve and manage in a sustainable way: areas and ecosystems that require protection to safeguard their special value; threatened or endangered species of flora and fauna and their habitats; and species with the objective of preventing them from becoming endangered or threatened. 57 The LBS Protocol is a regional mechanism that assists the United Nations Member States in the Wider Caribbean Region to meet the goals and obligations of the United Nations Convention on the Law of the Sea (UNCLOS) and the Global Plan of Action for the Protection of the Marine Environment from Land-Based Activities (GPA).

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3 REGIONAL STRATEGY FOR THE ENVIRONMENTALLY SOUND MANAGEMENT OF USED OILS IN THE CARIBBEAN ISLAND STATES

The concept of a regional strategy implies that participating countries will work in partnership to coordinate the design and delivery of actions that support each of the strategy’s underlying goals and objectives, taking into account both national and regional perspectives. Although the Regional Strategy offers countries the flexibility to adopt their own policies and approaches to assure that used oils are managed in an environmentally sound manner, it is equally important to ensure that national variations, where they may exist, interface well within the context of a regional solution. 3.1 OPTIONS FOR THE ENVIRONMENTALLY SOUND MANAGEMENT OF USED

OILS Environmentally Sound Management (ESM) is defined under the Basel Convention (Article 2, paragraph 8) as taking all practicable steps to ensure that hazardous wastes or other wastes are managed in a manner which will protect human health and the environment against the adverse effects which may result from such wastes. Criteria specific to the ESM of used oils are specified in the Basel Technical Guidelines on Waste Oils from Petroleum Origins and Sources (Y8) and the Basel Technical Guidelines on Used Oil Re-Refining or Other Re-Uses of Previously Used Oil (R9). The Regional Strategy incorporates a 3-option approach for countries to manage used oils within a regional context. Each of these approaches is identified below and illustrated in Figure 3.1.1. In cases where it is practicable to do so, priority should be given to option 3 which supports Article 4.2(d) of the Basel Convention58.

Option 1

Export surpluses of used oils directly to countries with sufficient capacity for ESM-compliant recovery, treatment, stabilization, or destruction of used oils.

Option 2

Export surpluses of used oils to ESM-compliant regional collection centres for bulking and subsequent shipment to ESM-compliant facilities and operations for used oils.

Option 3

No need to export. Process all used oils with domestic ESM-compliant facilities and operations for used oil recovery, treatment, stabilization, or destruction.

For the purpose of this Regional Strategy, the term “ESM-compliant” implies conformity with applicable requirements of the Basel Convention and the Basel Technical Guidelines, the MARPOL Convention and its related guidance, national laws, and other criteria used to assure that facilities and operations subscribe to ESM.

58 Article 4.2(d) of the Basel Convention states that “each Party shall take appropriate measures to ensure that the transboundary movement of hazardous wastes and other wastes is reduced to the minimum consistent with the environmentally sound and efficient management of such wastes, and is conducted in a manner which will protect human health and the environment against the adverse effects which may result from such movement.”

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ESM options for the final disposition of used oils are illustrated in Figure 3.1.2 and described briefly in the paragraphs that follow. As indicated in Figure 3.1.1, all eligible collection, transportation, treatment, resource recovery, stabilization and destruction options for used oils must, first and foremost, meet applicable ESM criteria for facilities and operations, as specified under the Regional Strategy. It is recommended that resource recovery options for used oils (i.e. re-refining, re-processing, high temperature burning as fuel) be given priority to alternate options for final disposition (i.e. stabilization and destruction) in cases where they are proven to be technically and economically feasible. Activities not recommended as eligible end-uses or final disposition options for used oils under the Regional Strategy are outlined in Table 3.1.1. These activities were excluded due to the following reasons: they may pose elevated risks to human health and the environment; they are not considered to be environmentally sound (or more environmentally-conscious alternatives exist); and, in many cases, they are prohibited by law in many countries of the developed world. Figure 3.1.1: National Options for Managing Used Oils under the Umbrella of a Regional Strategy

The collection of used oils is generally anticipated to occur at port reception facilities (for ships and other watercraft), on-site where it is generated (at land-based industrial/commercial operations), or at collection centres that service the general public (at fixed or temporary land-based depots). It is important that regional and national used oil collection networks are comprised of adequate facilities, which are

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suitably equipped to effectively and efficiently service their respective clients and users in an environmentally and economically conscious manner59,60. This may include, for example, pumping stations for transferring liquids and/or sufficiently sized storage devices with secondary containment (e.g. dual walls, berms). In some cases, private service providers may be contracted to collect used oils. Figure 3.1.2: Environmentally Sound Management Options for the Final Disposition of Used Oils61

The deliberate mixing of used oils with chlorinated substances, chemical solvents, water, or solids should be strictly prohibited at collection sites. In most cases, it will be necessary to collect used oils that already contain or are suspected to contain chlorinated substances62, chemical solvents, or high water or solid content as separate waste streams to avoid contaminating larger batches of used oils with these impurities63. Quality testing will provide the information necessary to

59 All Party States to the MARPOL Convention must ensure adequate port reception facilities for Annex I (oil) and Annex II (bulk noxious liquid) wastes. In addition, Parties to voluntary annexes of the Convention must also ensure adequate port reception facilities for Annex IV (sewage) and Annex V (garbage) wastes. 60 Detailed criteria for adequate port reception facilities have been established by the Marine Environment Protection Committee of the International Maritime Organization. 61 Modified from the International Maritime Organization’s Comprehensive Manual on Port Reception Facilities. 62 Polychlorinated biphenyls (PCB) or polychlorinated terphenyls (PCT) may be found in some transformer oils, capacitor oils and/or circuit breakers. PCB and PCT are persistent, bio-accumulative, and toxic in the environment. They are also suspected carcinogens. Burned under unsuitable conditions, PCB and PCT generate toxic by-products of combustion, including dioxins and dibenzofurans. 63 It is generally recommended that used oils undergo quality testing to determine whether they can be mixed with larger batches of used oils or whether they require separate storage and/or transport for specialized (and more costly) processing.

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determine if the used oils collected are eligible for certain resource recovery (with or without pre-treatment) or destruction options. Table 3.1.1: Activities Not Recommended as Eligible End-uses or Final Disposition Options for Used Oils under the Regional Strategy

Category Ineligible End-uses or Final Disposition Options

asphalt extrusion and cutting stocks road construction64 dust suppression wood preservation (e.g. protection from termite infestation)

Civil Works

lubricating moulds for shaping concrete, bricks and polyurethane

re-use in hydraulic systems (e.g. dump trucks, jacks, machinery) corrosion protection for metal parts Vehicle & Equipment

Repair & Servicing lubrication of moving parts in small engines

crude dumping, and land or sewer disposal landfilling65 Disposal discharge to surface waters or sea66

open burning igniting fires for fire fighting training or practice ship incineration

Burning as Fuel & Incineration

small space heating / household furnaces (non-tropical climates)67

herbicides pesticides (vermin suppression) Agriculture treatment of livestock for parasite control (e.g. mange)

insecticides (e.g. larvicidal control of mosquitoes) Miscellaneous marking sports fields

Treatment generally involves de-watering and removing solids from used oils. Re-processing (identified as a resource recovery option in Figure 3.1.2) is also often considered to be an advanced form of treatment, which involves the removal of contaminants (e.g. heavy metals, surfactants, additives, etc.) to improve the quality of used oils for subsequent re-use in re-refining operations or fuel burning applications. The water and/or solid content found in tank washings (slops), residues (sludges), bilge water and dirty ballast water is typically higher than that found in other types of oily wastes encountered. The process of removing water and solids from used oils generally involves the use of primary, secondary and/or tertiary treatment technologies, which are applied in a graduated fashion. Primary treatment basically consists of gravity separation using settling tanks, plate separators and disc, drum or belt skimmers. However, gravity separation is unable to separate oil-water emulsions, and is consequently followed by some means of secondary treatment. Secondary treatment typically involves the addition of chemicals to break oil emulsions (using coagulation)68. Several types of secondary treatment technologies exist, including coagulation-flocculation and air flotation units, filters, hydroclones, centrifuges, molecular coalescence oil-water separators, and

64 It is claimed that heavy bottoms from recycling processes (which are difficult to dispose of) can be used to enhance the performance of road asphalt when blended into modified and multi-grade bitumen. Given that many of the contaminants found in used oils are toxic to human health and the environment, this practice is not advised, particularly in the absence of an environmental risk assessment. 65 The landfilling of used oils is not recommended because the Caribbean pilot countries do not possess hazardous waste landfill disposal facilities, and used oils pose a flammability hazard and may leach off-site causing the contamination of surface or ground water. Furthermore, many developed countries prohibit the landfill disposal of used oils. 66 In the case of ships, the disposal of used oils at sea must be consistent with the requirements of the MARPOL Convention, the United Nations Convention on the Law of the Sea and other applicable legislation. 67 The burning of used oils in small space heaters and household furnaces is not an issue in the Caribbean region. 68 Coagulating agents such as iron or aluminium salt, or charged polymers are often used to break the oil emulsions.

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membrane separation. A description of each is presented in Annex E. Tertiary treatment is generally required to effectively treat oily wastes that contain chemical solvents. It involves the use of a biological treatment unit, in which wastewater is aerated and directed into an activated sludge tank, where microbes digest dissolved organic matter (including oil). The wastewater is then polished even further using a settling tank, to allow for the gravity separation of remaining suspended solids, before its final discharge. Resource recovery basically involves two principle end-uses for used oils: re-processing/re-refining, and high temperature burning as a fuel (often referred to as energy recovery). Sometimes used oils can be blended with crude oil for processing at traditional oil refineries (in a process known as slipstreaming), however this end-use option is generally only deemed to be viable for managing relatively small volumes of used oils. Re-processing and re-refining involve the separation and removal of contaminants to produce progressively higher grades of recycled oil for reuse. Re-processing uses relatively basic physical/chemical treatments such as settling, dehydration, flash evaporation, filtration, coagulation and centrifugation to generate oils intended for less demanding (primarily industrial) applications. In contrast, re-refining uses more advanced processes (e.g. hydrogen pre-treatment and/or vacuum distillation followed by clay or chemical treatment) to generate oils that are comparable to virgin oil products69. In some cases, re-processing may be applied as a pre-treatment to end-uses involving re-refining and/or the high temperature burning of used oils as fuel. However it should be noted that re-refining is not always an economically viable solution. Re-refined base oils generated from low cost technologies (e.g. filtration, centrifuge, acid-clay treatment) may not meet the technical criteria for most lubricant applications and therefore experience low demand in the consumer market. Conversely, high quality re-refined base oils that can be produced by distillation and hydro-treating requires significant capital investments ($15 - $30 M USD for a 45 kT/year plant), the economic viability of which is contingent upon the availability and quality of sufficient used oil feedstock, and the market demand for re-refined base oils70. Most re-refined lubricants, and all of those certified by the American Petroleum Institute (API), meet the same performance standards and engine and automobile manufacturer's warranty requirements as virgin oil products. High temperature burning of used oils as a supplementary or principle source of fuel71 is a common resource recovery option, particularly in cases where oil re-refining capabilities do not exist or are considered to be cost prohibitive. Burning used oils as a source of fuel helps to conserve and/or offset the need for other sources of energy, including non-renewable fossil fuels (e.g. virgin oil, coal, natural/liquid gas), renewable power (e.g. solar, wind, or hydroelectric power), and other waste-derived fuels (e.g. tire derived fuels, plastics). It is essential, however, that only properly maintained facilities/equipment that are specifically designed and approved for the combustion of used oils be used for this purpose72. Existing 69 It is estimated that 20,000 - 25,000 tonnes / year of used oils is required for re-refining to be profitable. 70 The anticipated market price differential between virgin lubricating oil products and re-refined lubricating oil products, coupled with the opinion of the general public concerning the equivalency of these products for use, should also be taken into consideration when assessing the economic viability of re-refining used oils. The prevalence of low cost combustion options for used oils will also have a significant bearing on the cost-effectiveness of re-refining operations for used oils. 71 The calorific value of new and used oils is approximately 43,000 kJ/kg (18,000 BTU/gallon) and 38,000 kJ/kg (14,000 BTU/gallon) respectively. In 2004, the cost of virgin fuel oil and used fuel oil in Jamaica was $0.13 USD and $0.06 USD accordingly. The monetary values for each have undoubtedly increased with the increasing cost of crude oil. 72 Used oils burners range in capacity from 50 kW to 2.5 MW, and atomize and/or vaporize used oils for combustion.

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equipment may also be retrofitted to burn used oils73. It is equally important to ensure that used oils are tested before they are used as a fuel source to verify that they meet applicable quality specifications as identified in national legislation and/or the Basel Technical Guidelines74. In cases where contaminants exceed allowable thresholds for used oils that are intended for use as a source of fuel, used oils must undergo re-processing. High temperature combustion is specified because low temperature combustion of used oils is more likely to generate combustion by-products which contribute to air pollution (e.g. metal oxides, PAH, sulphur dioxide, etc.). For this reason, it is recommended that used oil fuels be limited for application at medium to large-scale industrial or commercial facilities, such as cement and pottery plants, steel plants, asphalt plants, power generating stations, textile and linen plants, and distilleries that employ used oils to fire kilns, furnaces and boilers75. In cases where resource recovery is not a practicable option, the Regional Strategy recommends the destruction of used oils. Destruction may involve high temperature incineration or the use of land farms and/or biopiles. High temperature incineration is generally a suitable disposal option for organic wastes, including used oils76. Specifically, high temperature incineration is recommended for the destruction of used oils that may contain PCB, PCT, and other toxic or dangerous organic wastes. In contrast, wastes consisting primarily of inorganic matter are not good candidates for incineration. High temperature incineration (i.e. above 1200°C) is specified to minimize the formation of combustion by-products. High temperature combustion is also necessary to facilitate the removal of chorine (e.g. from used oils containing chlorinated solvents) by minimizing the formation of chlorine gas which is difficult to recover. Incinerators should be equipped with specialized flue gas recovery and neutralization systems (e.g. wet scrubbers) to properly manage combustion by-products, including chlorine, sulphur and metal oxides. It is also important to note that the type of incinerator used should correspond to the type of oily waste to be burned77. For example, the incineration of brine wastes containing oily residue may require specialized equipment (e.g. the use of declined combustion chambers) to facilitate the removal of inorganic molten salts. In other cases, particle size reduction (via crushing, grinding and shredding) may be required prior to the incineration of oily sludges and other solid wastes. The presence of PCB, PCT and other chlorinated substances in used oils also requires the use of specialized incineration facilities78. Wherever feasible, consideration should be given to the use of incinerators equipped with on-site heat recovery systems (e.g. for steam production). Land farms and biopiles are less frequently applied as a final disposal option for used oils. Both involve the bioremediation of used oils, whereby oily wastes are mixed with soil and periodically tilled or aerated to facilitate the decomposition of organic compounds by micro-organisms79,80. Sometimes nutrients (nitrogen or

73 For example, a modest investment of $5,000 - $20,000 (USD) is required to convert a boiler to burn used oils as fuel. 74 Basel Technical Guidelines on Used Oil Re-Refining of Other Re-Uses of Previously Used Oil (R9). 75 The hotel industry tends to use liquefied petroleum gas (butane or propane) to fire boilers which tend to be incompatible with the burning of used oils. 76 Wastes with calorific values above 18.6 MJ/kg (8,000 BTU/lb) are able to maintain a flame in incinerators, while with heating values below 11.6 MJ/kg (5,000 BTU/lb) will need an auxiliary fuel for combustion (and result in increased operating costs). 77 Several types of incinerators exist for used oil, such as rotary kiln, multiple hearth, fluidized bed, conventional furnaces and vortex systems. 78 For example, incinerators constructed of stainless steel which is corrosion and acid resistant is required due to the formation of hydrogen chloride and/or hydrochloric acid. 79 Waste oil is stored in a tank located on-site prior to treatment and applied to land farms or biopiles in a controlled fashion. 80 Anaerobic digestion is not commonly used to treat petroleum hydrocarbons and may actually prolong the rate of decomposition and contaminant reduction.

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phosphate rich fertilizers) are introduced to accelerate decomposition81. It should be noted however that bioremediation does not effectively treat metals82 or polycyclic hydrocarbons containing four or more rings. For this reason, the soil used for bioremediation must be removed for final disposal following several treatment cycles. The main difference between land farms and biopiles is that biopiles are engineered facilities in which the oily soil mixture is deposited into containment cells which are several feet deep and may be equipped with aeration and moisture conditioning pipes. The soil quality in these cells must also be closely monitored to facilitate decomposition, resulting in higher operating costs than land farming. The principle advantage of biopiles over land farms is that they require much less land space83,84. These space-saving benefits may justify the higher operational costs for biopile facilities, particularly in cases where land space is at a premium. Careful consideration to the design and siting of land farms and biopiles is necessary to minimize the potential risk of used oils and contaminants migrating off-site. The stabilization of oily wastes should only be pursued as a last resort. As indicated in Table 3.1.1, landfilling is not identified as an eligible final disposition option for used oils. Consequently, landfilling has only been identified as an option for oil-free solids (see Figure 3.1.2) that may emerge as process wastes from other phases of used oil management85. Controlled storage involves the use of a dedicated engineered facility to permanently store oily wastes with a low hydrocarbon content (less than 3%) and a high solids content. It may also entail pre-treating used oils with binding agents (e.g. lime with additives) to render the waste physically and chemically inactive before encapsulating the waste in an impermeable and waterproof enclosure. Almost no destruction of the waste takes place in this state, consequently the groundwater should be monitored regularly for potential contamination. Additional provisions may also be required for the controlled storage of chemical wastes, such as the need for leachate collection systems and moveable roofs. 3.2 PRODUCT SCOPE Industrial and non-industrial land-based sources and ship-generated wastes have been identified as principle sources of used oils in the Caribbean region. Used oils, under the scope of this Regional Strategy, refer to semi-solid or liquid used products that contain, in full or part, petroleum-derived (mineral) or synthetic86 oils which have been altered during use, and consequently are no longer suitable for their original intended application due to the presence of contaminants or impurities or the loss of original properties. In some circumstances, used oils may also pertain to unaltered residuals of mineral or synthetic oils typically found in containers and other storage devices. Specifically, used oils targeted under this Regional Strategy refer to those oils which are available for collection after use and identified in Box 3.2.1. 81 In a biopile, an initial oil content in soil of 100 mg/kg (or an oil content in soil of 10% by weight) oil can be reduced to 1.12 mg/kg (or an oil content in soil of 0.01% by weight representing a 98.88% reduction of oil) after a treatment period of 6-months. 82 Trace metals are typically immobilized in the top 12-18” of soil in land farms. 83 A land space requirement of approximately 0.5 m2/L of used oils over a 4-month treatment cycle is identified for land farming. By comparison, a land space requirement of 10 m2 /m3 of used oils per year was estimated for a biopile facility in Belize. 84 Land farming necessitates that land be left fallow for several years before it can be returned for agricultural use. The potential health implications of eating crops farmed on land previously used for land farming is not well understood. 85 Ideally, engineered landfill facilities should be used wherever possible to minimize the potential for leachate migration and groundwater contamination. 86 Synthetic oils are similar in composition to those found in petroleum base oils, but synthesized using chemical processes to combine basic carbon and hydrogen compounds. Generally, synthetic oils are incorporated as additives to enhance the physical and chemical properties of petroleum distillate feed stocks.

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Box 3.2.1: Types of Used Oils for Inclusion under the Regional Strategy

USED OILS FOR COLLECTION

1. gasoline or diesel engine oil 2. industrial gear oil or car differential oil 3. power steering oil 4. manual or automatic transmission oil 5. circulating oil or turbine oil 6. refrigeration system oil 7. mineral oil, polyalphaolefin (PAO), or diester

based compressor oil 8. heat transfer oil 9. electrical insulating oils (e.g. transformer

dielectric oils) 10. hydraulic or trans-hydraulic system oil 11. marine engine oil 12. oily tank washings (slops) 13. oily solids (sludges) 14. oily ballast water (from oil tankers) 15. oily bilge water 16. mixed oily liquids

OTHER USED OIL RESIDUALS*

17. machine tool oil 18. non-soluble cutting oil 19. drawing, stamping or shaping oil 20. two-stroke engine oil 21. drilling oil 22. form oil 23. textile oil 24. pneumatic system oil 25. quenching oil 26. chain oil (industrial or power chain saw) 27. process oil 28. saw guide oil 29. dust control oil 30. conveyor lubricating oil 31. penetrating oil 32. rustproof oil * Other used oil residuals (i.e. items 17 - 32) only apply to

the collection of used oil containers and used oil filters.

Used oil containers and used oil filters that may contain residual quantities of any of the used oils identified in Box 3.2.1 (i.e. items 1 - 32) should also be considered for environmentally sound management under the purview of the Regional Strategy. Specifically, these activities should focus on the extraction of residual oil from containers and filters via processes such as shredding, puncturing and/or crushing. The remaining plastic and metal wastes87 must also undergo environmentally sound management88. If the inclusion of used oil products is pursued, it is recommended that containers used for marketing oil (with a capacity of 50 litres or less) and used filters identified in Box 3.2.2 be targeted. Box 3.2.2: Types of Used Oil Filters Specified for Inclusion under the Regional Strategy

1. spin-on or element style filters used for gasoline or diesel-operated internal combustion engines, and hydraulic or

transmission applications 2. plastic / paper element style filters 3. sump type automatic transmission filters 4. coolant filters 5. fuel filters used at storage tanks, and retail and commercial pump islands

The potential inclusion of other types of used oils (e.g. vegetable-based oils, commercial cooking oils), and used oil products (e.g. aerosol cans, oily rags, bilge pads) under the context of the Regional Strategy should also be considered on a case-by-case basis, and agreed upon at a regional and/or national level in conjunction with waste management authorities and industry experts89.

87 Approximately 80 - 85% of an oil filter is composed of steel. 88 As used oil containers and used oil filters may still contain residual amounts of used oil following extraction, consignments of these products for recycling or final disposal must be treated as hazardous wastes. 89 Only used oils which are not consumed during use (i.e. support collection at the post-consumer stage) and are associated with readily available and economically feasible end-uses or final disposition options should be considered for inclusion under the Regional Strategy.

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3.3 MISSION STATEMENT The Mission Statement defines the purpose of the Regional Strategy, and helps to guide activities that take place in the present during times of uncertainty. To manage used oils, utilizing a regional approach, in an economically and environmentally sound manner, using practices consistent with the Basel Convention and the Basel Technical Guidelines90, and the MARPOL Convention and its related guidance91. 3.4 VISION STATEMENT The Vision Statement describes the desired outcome that the Regional Strategy aspires to achieve in the future. It may serve as a benchmark to determine whether course corrections are needed along the way to achieve intended results. To strengthen existing and establish new national polices and programmes that support the environmentally sound management of used oils in a regional context. 3.5 GOALS Goal 1: Secure commitment from relevant stakeholders to promote ESM for

used oils in accordance with the Basel Convention and the Basel Technical Guidelines, and the MARPOL Convention and its related guidance.

OBJECTIVES:

Short-term (up to 1 year) 1.A Identify relevant stakeholder organizations that share an interest in promoting ESM for

used oils and seek their endorsement in the implementation of the Regional Strategy. 1.B Secure formal commitment from the senior management of stakeholder organizations to

promote ESM for used oils and implement the Regional Strategy. 1.C Establish national steering committees for managing used oils, with representation from

interested stakeholder organizations, to plan, coordinate and monitor progress of country-specific activities to fulfil the Regional Strategy.

1.D Establish a regional steering committee for managing used oils to help address and coordinate regional issues and activities by programming and coordinating meetings.

1.E Formalize the mandate, composition, decision-making process, reporting structure, meeting frequency and other operating procedures for national and regional steering committees for managing used oils.

1.F Prepare, via national steering committees for managing used oils, National Action Plans that clearly define roles and responsibilities, and include a detailed financial management plan and budget with timeframes for country-specific activities in support of the Regional Strategy.

1.G Identify and allocate resources from stakeholder organizations and other support groups for use in implementing the Regional Strategy and National Action Plans.

90 These include the Basel Technical Guidelines on Waste Oils from Petroleum Origins and Sources (Y8) and the Basel Technical Guidelines on Used Oil Re-Refining or Other Re-Uses of Previously Used Oil (R9). 91 The MARPOL Convention related guidance includes the International Maritime Organization’s Comprehensive Manual on Port Reception Facilities.

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Long-term (up to 5 years) 1.H Review country performance in meeting objectives under the Regional Strategy, and take

corrective action, where necessary, to ensure that goals, objectives and timeframes are achieved.

1.I Review National Action Plans and national collection and management programs for used oils to ensure that they are coordinated and share consistencies on a regional basis.

1.J Re-secure formal commitment from country governments and other stakeholder organizations to promote ESM for used oils and implement the Regional Strategy in the event that there is a change in leadership or senior management.

Goal 2: Assess the degree to which the ESM of used oils are supported at

the national level. OBJECTIVES:

Short-term (up to 1year) 2.A Identify and record all facilities and operations (in both formal and informal sectors) that

generate, collect, store, transport, treat, recycle (i.e. re-refine, re-process, burn as fuel) and dispose of used oils.

2.B Assess whether existing facilities, operations and ships that generate and/or manage used oils comply with applicable national laws, and conform to the Basel Convention and the Basel Technical Guidelines, and the MARPOL Convention and its related guidance.

2.C Establish regional training programs in partnership with the Caribbean Basel Convention Regional Centre and International Maritime Organization to instruct government officials on how to conduct, prepare and maintain a national inventory for used oils that shares regional consistencies.

2.D Complete a national inventory for each country to determine the sources, quantities and types of new oils that are sold for domestic use, and used oils that are generated and collected for resource recovery (i.e. re-refining; re-processing; use as a fuel), destruction (i.e. incineration; land farming; biopiles), or stabilization (i.e. controlled storage) each year.

Mid-term (up to 3 years) 2.E Develop and maintain a regional used oil database to consolidate and track national

used oil inventory information in the region. Goal 3: Ensure national laws and compliance programs are sufficient to

ensure the ESM of used oils. OBJECTIVES:

Short-term (up to 1 year) 3.A Identify existing national legislation and international conventions that pertain to both

land-based and ship-generated used oil management. 3.B Assess whether existing national laws provide an appropriate level of protection to

human health and the environment from the potential risks associated with the collection, storage, transport, treatment, recycling, and final disposal of used oils.

3.C Assess whether existing national laws applicable to used oil management are enforced and contain suitable deterrents to dissuade unlawful conduct.

3.D Review the laws and collection initiatives of other countries for possible use as model legislation and programs to address national needs for used oils that may exist92.

3.E Identify whether imports and exports of used oils comply with national laws and fully incorporate commitments made under the Basel Convention.

3.F Identify whether the management of used oils by ships and port reception facilities comply with national laws and conform to the MARPOL Convention.

3.G Identify and assess opportunities to harmonize national laws for the management of used oils on a regional basis, while respecting each country’s sovereignty.

92 For example, laws concerning the collection of used oils in Canada (i.e. provinces of Western Canada, Atlantic Canada and Quebec), Europe (e.g. Germany, Italy, Sweden, France), and Australia may be used as model legislation. The American Petroleum Institute also established model legislation for used oil recycling in 1994, which has since been customized for use in the US states of California, Maine, South Carolina, Delaware , Maryland, Tennessee, Florida , Minnesota, Texas, Kansas, Missouri, Utah, Kentucky, New Hampshire, Virginia, Louisiana, and Rhode Island.

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3.H Assess the need for product take-back or extended producer responsibility legislation to enhance the recovery of used oils under national programs.

Mid-term (up to 3 years) 3.I Establish regional training programs in partnership with the Caribbean Basel Convention

Regional Centre and International Maritime Organization to instruct government officials, as necessary, on how to fulfil provisions applicable to the management of used oils under the Basel and the MARPOL Conventions.

3.J Establish in-house national training programs for government officials on national legislative requirements pertaining to used oil management and facility operations.

3.K In consultation with governments of the region, implement actions to harmonize legislation pertaining to the ESM of used oils in conformity with the provisions of the Basel and the MARPOL Conventions.

3.L Develop compliance promotion programs targeting collectors, transporters, processors, marketers, end-users and disposal agents of used oils to raise awareness regarding national laws and other requirements applicable to their operations.

Long-term (up to 5 years) 3.M Develop new or amend existing national laws, as deemed necessary, to correct

regulatory deficiencies that may be applicable to the ESM of used oils. 3.N Promote the design and implementation of national technical standards for the ESM of

used oils in accordance with the Basel Convention Technical Guidelines and the MARPOL Convention guidance documentation.

Goal 4: Implement national programs (in a regional context) to collect

used oils for ESM. OBJECTIVES:

Short-term (up to 1 year) 4.A Establish regional criteria for use in accrediting used oils facilities and operations that

subscribe to ESM. 4.B Identify and review options for the environmentally sound collection, storage, transport,

treatment, resource recovery and final disposal of used oils at the national and regional level with minimal cost and impact to human health and the environment.

4.C Assess the economic and technical feasibility of establishing new or enhancing existing domestic capacity for the environmentally sound collection, storage, transport, treatment, resource recovery and final disposal of used oils.

4.D Identify and review options for roles and responsibilities of government, oil producers, oil marketers, oil consumers, waste haulers, and end-users of used oils under a national collection and management program for used oils.

4.E Devise a regional template to assist countries to develop national collection and management program plans for used oils and to encourage a harmonized approach to program delivery throughout the region.

Mid-term (up to 3-years) 4.F Identify, certify and register national ESM-compliant facilities and operations for the

collection, storage, transport, treatment, resource recovery and final disposal of used oils using the regional criteria for ESM.

4.G Work with industry and investors to establish or enhance domestic capacity to provide environmentally sound collection, storage, transport, treatment, resource recovery and/or final disposal for used oils, if assessed to be economically and technically feasible.

4.H Provide training programs to assist facilities and operations in meeting regional criteria for certifying ESM-compliant facilities and operations for managing used oils.

4.I Prepare national collection and management program plans93 for the collection, storage, transport, treatment, resource recovery and final disposal of used oils using ESM-compliant facilities and operations.

4.J Identify how performance will be measured and reported under national collection and management programs for used oils.

93 National collection and management program plans should subscribe to the waste management hierarchy whereby the following activities are favoured in order of priority: prevention, minimization, re-refining and re-processing, use as a fuel, and final disposal. It should be noted however that applications identified in Table 3.1.1 are not recommended as eligible end-uses and final disposition options for used oils under the Regional Strategy.

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4.K Design a regional template for use in preparing annual performance reports for national collection and management programs for used oils.

Long-term (up to 5 years) 4.L Implement national collection and management programs for used oils. 4.M Periodically audit ESM-compliant facilities and operations to assure ongoing conformity

with regional criteria for the ESM of used oils. 4.N Prepare annual reports that document and validate program performance and costing

following each calendar year period of the national collection and management program. Goal 5: Implement financial mechanisms to support the delivery and

effectiveness of national collection and management programs for used oils.

OBJECTIVES:

Short-term (up to 1 year) 5.A Establish regional guidelines for the use of economic instruments and financial

intervention options in national collection and management programs for used oils. 5.B Assess the need for collection and transportation incentive payments to defray the

associated costs of used oils collection, storage, handling, transport and shipping, especially in rural and remote communities.

5.C Identify and review options for economic instruments to promote the return of used oils by consumers for ESM in the formal sector.

5.D Identify, review and document economic instruments and financial intervention options to ensure the long-term economic sustainability of national collection and management programs for used oils.

5.E Identify sources of start-up capital that may be necessary to initiate delivery of national collection and management programs for used oils.

Mid-term (up to 3 years) 5.F Identify operations and procedures for use in administering national collection and

management program revenues to ensure that program expenditures are explicitly linked to the management of used oils.

Long-term (up to 5 years) 5.G Audit and report national collection and management program revenues and

expenditures following each calendar year period of operation (linkage to objective 4.N). Goal 6: Compel facilities and operations, for which existing approaches to

managing used oils are considered to be inadequate and/or problematic, to adopt improvements for the ESM of used oils.

OBJECTIVES:

Short-term (up to 1 year) 6.A Identify, visit and document facilities and operations for which existing approaches to

managing used oils are considered to be inadequate and/or problematic from a human health and/or environmental perspective.

6.B Identify and disseminate practical and economically feasible options for improving the manner in which used oils are managed at the types of facilities and operations identified in objective 6.A (linkage to objective 4.A). See Box 2.3.2 for examples.

6.C Identify, review and implement national policies, programmes and mechanisms, including financial intervention options and other supportive measures, to assist facilities and operations in acquiring the expertise, equipment and/or services necessary to bring about improvements which are deemed to be necessary by government authorities (linkage to objective 5.A).

6.D Persuade facilities and operations to adopt formalized plans, procedures, and/or services for managing used oils in an environmentally and economically sound manner.

6.E Provide training to employees of facilities and operations on applicable legal requirements and best management practices for used oil management to minimize the risk of personal injury and to help protect human health and the environment (linkage to objective 7.C).

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Mid-term (up to 3 years) 6.F Establish and disseminate guidance to assist the types of facilities and operations

identified in objective 6.A in addressing issues related to spill prevention and spill contingency planning.

6G On a priority basis, revisit facilities and operations identified in objective 6.A to ascertain whether improvements have been implemented.

Long-term (up to 5 years) 6.H Enlist facilities and operations to participate in national collection and management

programs for used oils (linkage to objective 4.L). 6.I Formally charge the employees of facilities and operations that continue to knowingly

contravene national laws and international conventions applicable to the management of used oils, despite warnings and best efforts to encourage legitimate conduct.

Goal 7: Raise public awareness concerning the need for and importance

of the ESM of used oils. OBJECTIVES:

Short-term (up to 1 year) 7.A Establish community liaison groups through non-government organizations in the region,

the BCRC-CARIBBEAN, and the International Maritime Organization to raise awareness regarding the importance of ensuring ESM of used oils.

7.B Develop and implement general communication plans and tools to inform consumers about the types of things that they can do to help foster the ESM of used oils.

7.C Develop targeted communication plans and tools to discourage questionable end-uses for and improper disposal of used oils (see Table 3.1.1) in communities and vocations where these activities are found to be prevalent.

7.D Assess and raise the level of awareness within the public and private sectors regarding applicable legislation governing the collection, storage, transport, treatment, recycling and final disposal of used oil, as well as the provisions of the Basel and the MARPOL Conventions.

7.E Assess and raise the level of awareness within the general public, civil society and other stakeholder groups regarding the potential risks to human health and the environment of improper used oil management, the importance of managing used oils in an environmentally sound manner, and the existence of national and/or regional collection and management programs for used oils.

Long-term (up to 5 years) 7.F Develop and incorporate courses on environmental protection matters, including

hazardous waste management, in the curriculum of all educational levels. Goal 8: Identify remediation sites where contamination from used oils has

been observed. OBJECTIVES:

Short-term (up to 1 year) 8.A Identify the relevant agencies that are involved in the assessment of contaminated sites

and the appropriate follow-up actions to ensure their remediation. 8.B Develop and implement national protocols to guide the remediation of contaminated sites. Goal 9: Promote technical assistance, including capacity building and

technology transfer, to enhance the ESM of used oils in the region. OBJECTIVES:

Short-term (up to 1 year) 9.A Identify and consider the utilization and sharing of clean technologies and environmentally

conscious alternatives to support the ESM of used oils in the region, where appropriate.

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9.B Identify and share regional technical expertise and resources, where it exists, which support the ESM of used oils.

9.C Implement training courses for key public sector groups, primarily customs and enforcement officers (linkage to objectives 2C, 3I, and 3J).

9.D Identify and solicit technical expertise and resources, where it resides outside the region, to strengthen the capacity of GRULAC countries to address issues related to the ESM of used oils.

Mid-term (up to 3-years) 9.E Identify industry best practices that are applicable for use in the region and promote their

adoption, including industry environmental and product stewardship initiatives. 9.F Encourage industry to assist in capacity building and knowledge transfer within the formal

sector to support the ESM of used oils at the national level. Long-term (up to 5 years) 9.G Promote research and development of cleaner production technologies and

environmentally conscious end-uses for used oils for application in the region. 3.6 ANALYSIS OF THE STAKEHOLDERS A number of existing and potential stakeholders have been identified throughout the planning and implementation stages of this regional initiative. Figure 3.6.1 identifies the relationship of these groups while Table 3.6.1 identifies existing/potential roles of these groups to support delivery of the Regional Strategy. Companies that could potentially participate in the regional used oil initiative are identified in Table 3.6.2. Figure 3.6.1: Relationship of Stakeholders Contributing to the Regional Strategy

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Table 3.6.1: Existing/Potential Roles for Regional Strategy Stakeholders

Category Organization Existing/potential roles

UNEP-SBC

Service the Basel Convention Ensure the necessary coordination with relevant international bodies Assist in the implementation of the 1999 Ministerial Declaration,

Strategic Plan for the Implementation of the Basel Convention to 2010, and the public-private partnership initiatives.

Solicit interest from international donors and supporters for partnership projects

Provide technical expertise and guidance on the design and delivery of the regional public-private partnership initiative

Report public-private partnership project outcomes to international donors and other interested Parties

BCRC-CARIBBEAN

Coordinate regional activities linked to the Basel Convention, 1999 Ministerial Declaration and Strategic Plan for the Implementation of the Basel Convention to 2010.

Liaise with Parties in the region to identify training needs and help address regional and country-specific needs

Facilitate and administer regional training and workshops related to the above based on the Basel Convention and the Basel Technical Guidelines, and the MARPOL Convention and its related guidance

Report public-private partnership project outcomes to UNEP-SBC

Coordinators

Regional Committee for

Managing Used Oils

Composed of select Party countries in the region Regional advisory body on regional issues linked to the design and

delivery of the Regional Strategy Help address regional needs to deliver the Regional Strategy Report regional successes and challenges to BCRC and other

regional stakeholders Also engaged in strategy implementation

National Committees for

Managing Used Oils

National advisory body on national issues linked to the design and delivery of the Regional Strategy

Develop and coordinate implementation of a National Action Plan for used oil

Help address country-specific needs to deliver the Regional Strategy and National Action Plan

Report national successes and challenges to Regional Steering Committee, national governments and other national stakeholders

Also engaged in strategy coordination Establish multi-stakeholder regional and national committees for used

oils Ensure that the national import and export of used oils conform to

existing laws and the Basel Convention Ensure laws are sufficient to protect human health and the

environment from risks posed by used oils Register ESM-compliant used oils facilities and operations Deliver public awareness programs to convey the importance of and

build support for ESM of used oils Provide necessary training on ESM and Occupational Health and

Safety to used oil handlers Implement financial mechanisms to support the environmentally sound

collection and recycling of used oils Foster support for clean technologies linked to the treatment, resource

recovery, destruction and stabilization of used oils Identify sites that may be contaminated with use oils

Implementers

Government

Institutional Linkages: 1. Ministry of Environment and Natural Resources 2. Ministry of Health and Labour 3. Ministry of Finance and Customs 4. Ministry of Industry and Commerce 5. Ministry of Transport 6. Ministry of Education 7. Solid Waste Management Authorities

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Table 3.6.1: Existing/Potential Roles for Regional Strategy Stakeholders

Category Organization Existing/potential roles Operate in accordance with national law, and applicable requirements

of the Basel Convention, Basel Technical Guidelines, and the MARPOL Convention

Share technical expertise on the ESM of used oils Upgrade facilities and operations where economically feasible and

seek ESM registration Provide training to employees on ESM and Occupational Health and

Safety (OH&S) Industry Institutional Linkages:

1. Collectors and transporters of used oil 2. Companies involved in the resource recovery, treatment,

destruction and/or stabilization of used oil 3. Oil producers, importers, and distributors 4. Trade / Industrial Chambers related to petroleum oil

Help to identify facilities and operations in which used oil management is a problem

Promote integration of clean production processes and technologies Raise public awareness regarding the hazards of used oils, and

promote ESM and safe operating procedures for used oils Environmental

non-Government Organizations Institutional Linkages:

1. Caribbean Environmental Health Institute (CEHI) 2. National Clean Production Centres 3. Recycling Councils

Update national inventories regarding the generation and final disposition of used oils

Help to design national used oil collection and recycling programs Academia Institutional Linkages:

1. Universities (e.g. University of West Indies) 2. Research Institutes (e.g. Caribbean Industrial Research Institute)

Raise public awareness regarding the hazards of used oils, and promote ESM and safe operating procedures for used oils

Other Implementers

Other non-Government

Organizations Institutional Linkages:

1. Media Provide in-kind technical expertise and support Provide technical training on ESM and used oil management, and the

MARPOL Convention and Cartagena Convention requirements that pertain to the management of used oils

International Supporters Institutional Linkages: 1. International Maritime Organization (IMO) 2. Secretariat of the Cartagena Convention (UNEP/RCU) 3. International donor agencies (listed below)

Support capacity building in developing countries Contribute financial resources to implement the Regional Strategy

International Donors

Institutional Linkages: 1. Andean Development Corporation (CAF) 2. Canadian International Development Agency (CIDA) 3. Department of Environment and Nature (MINA) of the

Netherlands Antilles 4. Environmental Foundations 5. Global Environmental Facility (GEF) 6. Inter American Development Bank (IADB) 7. Ministère de l’Ecologie et du Développement Durable (France) 8. North American Commission for Environmental Cooperation

(CEC) 9. Pan American Health Organization (PAHO) 10. UK Department of Environment, Transport and the Regions

(DETR) 11. United Nations Environment Conference on Trade and the

Development (UNCTAD) 12. United States Department of Commerce 13. United States Environmental Protection Agency (US EPA) 14. World Bank 15. World Health Organization (WHO)

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Table 3.6.2: Companies in Pilot Countries that Could Potentially Participate in the Regional Scheme

Country Company Name End-use / Facility Antigua & Barbuda West Indies Oil Company (WIOC) Biopile Bahamas N/A N/A

Arawak Cement Company Limited (St. Lucy) Cement Kiln Fuel Barbados National Terminal Company Limited (BNTCL) Petroleum Company Barbados National Oil Company Limited (BNOCL) Petroleum Company Barbados

Machinery & Allied Engineering Services (MAES) Limited Used Oil Hauler Belize Electricity Limited Electricity Generator Belize Shell Terminal Petroleum Company Nico Lopez Refinery Oil Refinery Hermanos Diaz Refinery Oil Refinery Cienfuegos Refinery Oil Refinery Manel Cement Factory Cement Kiln Fuel Siguaney Cement Factory Cement Kiln Fuel

Cuba

Santiago de Cuba Cement Factory Cement Kiln Fuel Dominica Dominica Electric Services (DOMLEC) Electricity Generator Dominican Republic Haina Refinery Oil Refinery Guyana N/A N/A

Petrojam Limited Petroleum Company Petroleum Company of Jamaica Limited (PETCOM) Petroleum Company Petroleum Corporation of Jamaica (PCJ) Petroleum Company Caribbean Cement Company Limited (Rockfort) Cement Kiln Fuel JPSCo Electricity Generator Esso Standard Oil S.A. Limited Petroleum Company Premier Waste Management Inc. Used Oil Hauler Texaco Caribbean Inc. (TEXACO) Petroleum Company Shell Company (WI) Limited (SHELL) Petroleum Company

Jamaica

Chevron Petroleum Company Royal Utilities Electricity Generator Saint Kitts & Nevis Trading and Development Company Limited (TDC) Fuel Marketer St. Lucia Distillers Limited Boiler Fuel Saint Lucia St. Lucia Linen Services Limited Boiler Fuel VINLEC Electricity Generator Saint Vincent & the

Grenadines Shell Petroleum Company Pointe-à-Pierre Refinery Oil Refinery National Petroleum Marketing Company Fuel Provider Oil Mop Services Oil Re-processor Earth Company Limited Oil Re-processor La Brea Industrial Estate Biopile

Trinidad & Tobago

Trinidad Cement Limited (Claxton Bay) Cement Kiln Fuel

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3.7 AN OVERVIEW OF COMMON APPROACHES TO FINANCING THE ESM OF USED OILS

Waste products that are improperly discarded result in higher costs to society because they become a nuisance issue (e.g. litter) and/or pose risks to human health and the environment. Improperly discarded wastes are also quite expensive to redirect into legitimate and environmentally sound waste management programs. To address this problem, many countries have established “take-back” programs for a number of product-focused waste streams, including used oils (and used oil containers and used oil filters). Consumer participation, in the form of taking back products at the end of their useful life, is a critical element that often defines the overall success of these programs. Product take-back programs may employ a variety of economic instruments and incentives to encourage the collection of used oils and generate sufficient revenue to cover program expenditures. Although instrument selection (and their associated program design) may vary on a case-by-case basis, it is important for decision-makers to carefully evaluate and compare the potential environmental, social and economic costs and benefits of all proposed options before making a final selection. In addition, inconsistently applied or variable incentives/disincentives within the same geographic region may also lead to market place distortions for product purchasing and return (particularly under voluntary approaches). However, it should also be emphasized that financial intervention options must apply equally to both domestic and imported goods and services, to do otherwise would establish a barrier to trade and contravene trading rules and regulations that exist under World Trade Organization (WTO) Agreements. Common approaches that have been used to finance existing product take-back programs for used oils are outlined in Table 3.7.1 and briefly described below, in the context of the scenarios with which they appear to be most commonly associated. In some cases however, it may be prudent to consider a combination of two or more instruments to ensure the economic sustainability of product take-back programs and stimulate consumers to return used oils to collection facilities. Advance Recycling Fees (Levies) In many cases, advance recycling fee (ARF) schemes have been popular for use in funding product take-back programs for used oils. An ARF is a surcharge or levy that is placed on designated products (e.g. used oil, used oil containers, used oil filters) to cover the estimated costs for their environmentally sound collection, transport and recycling after they have reached the end of their useful life94. They are typically used when other financial intervention options are, by themselves, not considered to generate desirable or effective results. Unlike “back-end” service charges (or disposal fees), illegal dumping as a means of fee avoidance is not an issue under ARF schemes.

94 ARF may also be used as a sustainable source of revenue for other program costs including assessing ESM compliance, reporting and auditing program finance and performance, communications, public relations, and general administration.

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Table 3.7.1: Economic Instruments and Incentives Applicable to Used Oil Management Instrument /

Incentive Pros Cons

Advance Recycling Fees (Levies) Noted examples: Western Canada & Quebec, Italy, Australia, California (USA)

Extended Producer Responsibility (EPR) programs are managed and/or financed by producers, first importers and/or first sellers of oil products

Levies provide a sustainable revenue stream to pay for all costs of program delivery

Levies do not apply to oil products from which used oil can not be recovered after use

All aspects of program delivery are coordinated using a centralized approach (e.g. oversight body) which may facilitate ESM and performance measurement

Revenues may be used to offer return incentives to collectors and transporters, and encourage infrastructure development

No direct financial incentive for consumers to return products to collection points

Levies are typically passed down through the product-supply chain to consumers

Program revenues and expenditures may be higher than other options if not carefully controlled, resulting in public mistrust

Government-operated programs may allocate revenue from levies for purposes other than managing used oils

Back-drop legislation is usually necessary to ensure full industry participation in program delivery

“Added Value Service” Noted examples: Atlantic Canada, Germany

No levies are imposed on the sale of oil products

All retailers that sell oil products provide collection services for used oils free-of-charge to consumers

Return-to-retail is convenient for most consumers

Retailers benefit from the potential for repeat business

Retailers may be able to negotiate the sale of used oils to licensed end-users


Does not raise program revenue, retailers must internalize the costs of program delivery

Retailer benefits may not completely offset expenses for used oil management

Product collection that does not occur at the point-of-retail, may negate retailer opportunities for repeat business

Acquiring program performance data from individual retailers may be problematic

Back-drop legislation is usually necessary to ensure full retailer participation in program delivery

Service Charges Noted examples: private sector service providers (e.g. garages, waste haulers, ports, etc.)

Follows a traditional approach to waste management in which private sector services are funded through service charges

Service charges tend to be moderated by competition in the free market economy

Many businesses already charge service charges for managing hazardous wastes, including used oils

Service charges may be cost prohibitive in rural or remote areas that are situated far from final disposition facilities for used oils

“Back-end” service charges may contribute to the illicit disposal of used oils as a means of fee avoidance, especially in poorer communities

Tax-base Funded Schemes Noted examples: waste collection programs run by public waste management authorities

Follows a traditional approach to waste management in which community services are funded through taxes

General tax laws are already in place Programs generally target a wide variety of

hazardous or difficult to manage waste streams, not just used oils


Burden of program funding is placed on government and general tax payers (versus producers and product consumers)

Government resources may be insufficient to ensure permanent recovery programs for urban, rural and remote communities

Sustainable program financing may necessitate tax-hikes or resource diversion from other community services, both of which are not favoured politically or publicly

Deposit-Refund Schemes Noted examples: none identified

Refund component provides a direct financial incentive for consumers to return used oils

Modelled after the “polluter pays” principle Non-refundable portions of a deposit (levy)

can be used to offset program carrying costs Return-to-retail is convenient for most

consumers May be combined with advance recycling fees

Retailers (versus producers) are responsible for program delivery

Unredeemed deposits may not completely offset retailer expenses

Acquiring program performance data may be more problematic under de-centralized approaches

Retailer imposed conditions concerning refund claims may frustrate consumers

Back-drop legislation is usually necessary to ensure full retailer participation in program delivery

Tax Exemptions (Subsidies) Noted examples: none identified

Tax exemptions encourage specific capital investments, infrastructure development projects, process improvements and equipment purchases

Does not represent a sustainable resource of revenue for program delivery

Opposition to subsidies may emerge from public and private stakeholder organizations

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ARF, by themselves, do not provide consumers with direct financial incentives to return used oils to collection points and therefore require programs with strong public relations and communication campaigns to encourage and maintain consumer participation. However, an ARF could be integrated as a non-refundable portion of deposit-refund schemes to ensure that consumers remain financially motivated to return used oils if necessary (refer to deposit-refund schemes), although no examples of a levy-based deposit-refund scheme for used oils have been identified at this time. ARF are generally adopted in product take-back programs that are coordinated by a dedicated oversight body that is operated by industry, government, or a designated third-party organization. Each type of dedicated oversight body generates program revenue from either product levies that are charged directly to manufacturers and/or first importers of designated products, or product levies that are charged directly to consumers of designated products at the point-of-retail. In some cases, retailers are not required to accept used oils resulting in the need for separate collection facilities or depots. In situations where program revenues are generated from levies applied at the level of the manufacturer or first importer, individual companies must remit these levies, accompanied by a statement of their unit product sales, to the board of directors of a dedicated oversight body on a periodic basis. Proprietary information concerning individual company sales, revenues and market share is shared with the board under strict confidentiality agreements95 and used to validate that a company’s financial contribution to the collection and management program for used oils is proportionate to the number of products that it sells within the country. Often, individual manufacturers and first importers tend to recoup these levy costs by passing them down through the product supply chain to distributors, retailers and ultimately consumers (usually as a separate fee without mark up). Alternatively, manufacturers, first importers, distributors and/or retailers could make a conscious decision to absorb the cost of these levies (e.g. as part of a marketing strategy to gain more product sales). Program revenues that are generated from levies applied at the consumer-level are collected by retailers and remitted to dedicated oversight bodies on a periodic basis. Industry-operated dedicated oversight bodies are usually established under the auspices of Extended Producer Responsibility (EPR) programs, which obligate producers (e.g. manufacturers and first importers) to recover and manage the products that they introduce to the marketplace after consumers are finished using them. National law usually prescribes EPR requirements. Under EPR programs, producers generally prefer to work collectively in meeting their responsibilities, mainly due to the linkages that exist between economies of scale and cost-efficiencies of program delivery (e.g. to secure bargaining power in negotiating agreements with service contract providers). To facilitate this, a not-for-profit industry consortium (often referred to as a producer responsibility organization or PRO) is established and tasked with designing and implementing product take-back programs that fulfil applicable legal requirements96. Decisions of the PRO are made by a board of directors consisting of representatives from participating manufacturers 95 A PRO may, however, be required to disseminate industry product sales information in an aggregate form to the public. 96 Requirements of EPR legislation may include meeting prescribed targets for product collection and product recycling.

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and first importers. In some cases, representatives from government, environmental non-government organizations and the recycling industry are also invited to participate on the board in an effort to win public confidence for the initiative by ensuring transparency of program operations and avoiding any potential for industry collusion. The scheme described above has been adopted in the provinces of Western Canada and Quebec97, all of which provide collection services for both used oils and used oil products (i.e. containers and filters). The used oil management program in Italy is also overseen by a PRO98. The governance of an oversight body that is operated by a third party is very similar to that of a PRO. The chief difference however is the composition of the board structure, which tends to ensure that more of a balance between industry and non-industry representation exists for decision-making. A government-operated oversight body is, as the name suggests, simply a section of government that is principally tasked with controlling the financial aspects of program delivery and registering collectors, transporters and recyclers of used oils. These duties may also be partially administered by a private sector contractor under contract to government (or alternately a designated arms-length third-party oversight body). For example, Australia99 and the state of California100 in the USA have adopted product stewardship programs for used oils modelled after this approach, whereby revenue from product levies is placed into a government-managed environmental trust fund for use in funding program delivery. Generally, this revenue is used to offer registered industrial generators, curbside collection programs, and certified collection centers a direct financial incentive for each gallon of used lubricating oil that is collected for recycling. It is important however, that under these types of approaches, government organizations use this revenue for its intended purpose (i.e. to collect and manage used oils) and not to finance other environmental or social interests (in which case it would be perceived as a tax). Product levies established for used oils reflect the costs of providing services to collect and manage used oil in an environmentally sound manner minus any subsidies received from the sale of used oils on the secondary market (both of which may fluctuate over time). Consequently, the amount of the product levy may need to be adjusted periodically to maintain a balance between program expenditures and program revenues while avoiding the potential for large financial surpluses or deficits to accrue over time. It is also important to ensure cost-efficiency of program delivery, from the perspective of both administrative and operational expenses. In 97 Examples of PROs for used oils in Canada include the British Columbia Used Oil Management Association (BCUOMA), Alberta Used Oil Management Association (AUOMA), Saskatchewan Association Resource Recovery Corporation (SARRC), Manitoba Association for Resource Recovery Corporation (MARRC) and Quebec Société de gestion des huiles usagées (SOGHU). All brand owners, first suppliers or importers of oil products must remit an ARF of $0.05 CDN per litre of lubricating oil, $0.05 CDN per litre of capacity for containers of 50 litres or less, and $0.50 CDN per filter of less than 8 inches or 203 mm (in length), and $1 CDN per filter of 8 inches or 203 mm. (in length) and more. 98 In Italy, all lubricants attract a levy of €325 per tonne which is used to subsidize the operations of certain re-refinery and fuel manufacturing plants, test waste oil feedstock and promote used oil collection. The Italian Consortium of Used Oils which administers the program consists of representatives from the manufactures of lubricants, waste oil collectors, re-refiners and public regulators. 99 In Australia, oil producers and importers must remit a levy of 5.449 cents AUD per litre (or kilogram for greases) for the sale of petroleum-based oils and their synthetic equivalents to the Australian Department of the Environment and Heritage. Revenue from product levies are used to offset the costs of benefits paid to oil recyclers as an incentive to undertake increased recycling of used oil. 100 In California, manufacturers of oil must remit $0.16 USD to the California Integrated Waste Management Board (CIWMB) for each gallon of lubricating oil sold, transferred or imported for use in the state. Registered industrial generators, curbside collection programs, and certified collection centers are eligible to receive $0.16 for each gallon of used lubricating oil recycled.

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some cases, revenue is applied to provide transportation incentives by means of freight-equalized zone incentive payments101 which are calculated according to the associated costs of transporting used oils to final disposition facilities from specified geographic zones. In a similar manner, ARF-generated revenue could also be used to provide incentives for the collection of used oils for ESM and infrastructure development (e.g. facility construction). “Added Value Service” “Added value service” schemes generally obligate retailers of oil products to make available services for the collection and ESM of used oils which are free-of-charge to consumers. In some cases, retailers may elect to make use of independent facilities and services to meet these obligations in the event that they do not operate a return facility themselves. These schemes are commonplace in Atlantic Canada102,103 and Germany104. Collection services are typically offered during the regular operating hours of the retailer, and may be provided at the point-of-retail or a retailer-operated return facility that is located within a prescribed distance from the retailer’s establishment. For example, added value service approaches operated in the provinces of Atlantic Canada require that retailer-operated return facilities be located within 5-10 km from the seller’s premises. In addition, sellers of lubricants must clearly display notice of the location of these return facilities at the point-or-retail (or on oil packaging in the case of deliveries). Sometimes, return facilities may also impose limits on the quantities of used oils that will be accepted from individuals each day105 and maintain records of the types and quantities of used oils that are returned. Backdrop regulations are usually necessary to ensure full retailer participation in collecting used oils for ESM. Although vendors may incur additional costs associated with handling returns of designated products, it is presumed that these costs are offset by the potential for repeat business (i.e. when consumers return used oil)106. It may also possible for retailers to sell used oils to licensed end-users or have it hauled away for little or no charge, due to the fact that used oil is considered to be a marketable commodity. However, it should be noted that, due to the large number of independent retailers responsible for program delivery, it may be problematic for government authorities to assure that programs are delivered in a consistent fashion (e.g. conformity to ESM principles) and/or to consolidate data to provide an accurate measure of program performance107. Like ADF, added value service schemes do not provide consumers with direct financial incentives to return used oils to collection points.

101 For example, in Canada, the western provinces and Quebec have adopted freight-equalized zone incentive payments for used oils and used oil products. 102 Added value service schemes are commonplace in the provinces of New Brunswick, Nova Scotia, Prince Edward Island, and Newfoundland and Labrador. 103 The added value service approaches for used oils in Atlantic Canada do not include used oil containers and used oil filters. 104 Unlike Atlantic Canada, Germany provides government-funded financial assistance for re-refining/re-processing used oils. 105 For example, New Brunswick legislation requires a return facility to accept up to 25 litres of used oil per person per day, or the number of litres in the largest container sold by sellers. 106 Retailer-operated return facilities that are not located at the point-of-retail may negate this possible benefit. 107 Problems consolidating program performance data are commonplace when requirements do not exist for retailers to report to a centralized body on a periodic basis.

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Service charges Service charge funded schemes are generally operated by private sector service providers, which charge generators of used oils for the collection and/or removal of these materials for ESM. In reality, service charges generally represent the status quo, because private sector service providers are commonplace in most types of recycling and waste management schemes. For example, many waste haulers, garages, and port reception facilities already charge their clients “back-end” service charges for managing hazardous wastes, including used oils. Although service charges may vary, they do tend to be moderated by competition amongst private sector service providers in a free market economy. In some cases, service charges may be discounted due to the residual value of and market demand for used oils. In other cases, service charges may also be used to deter the return of used oils at facilities which lack adequate infrastructure for the collection of used oils (e.g. at select port reception facilities), however this practice is not advised for wide-scale application because it may inadvertently lead to illicit disposal. The availability of private sector services to collect used oils for ESM is contingent upon the market demand for these services and the economic feasibility of providing these services at a reasonable cost. Sometimes the service charges needed to generate a profit may be cost prohibitive, particularly in rural or remote areas that are situated far from final disposition facilities for used oils. In these situations, private sector ventures will undoubtedly require some additional form of subsidization for service delivery. It is also important to note that because service charges are only applied to products after they become a waste or recyclable material (i.e. a “back-end” fee), they may inadvertently contribute to the illicit disposal of used oils as a means of fee avoidance, especially in poorer communities. For this reason, many countries have moved towards product take-back programs that are financed using an “upfront” fee which apply to the purchase of designated new products. Tax-base funded schemes Tax-base funded schemes use general tax revenue to fund community waste management services. Under these schemes, a portion of public tax revenue is allocated to government waste management authorities for general use in assuring that residential wastes (i.e. wastes that are not derived from industry or commercial activities) are collected for proper recycling or disposal. In many cases, this revenue is used to establish permanent or temporary collection services for the ESM of a wide variety of hazardous or difficult to manage wastes streams (e.g. electronics, paints, pesticides, pharmaceuticals, used oil, batteries, etc.). Tax-base funded schemes generally adopt a traditional approach to waste management whereby funding is acquired from public coffers. These schemes do not require new legislation because the legal authority for general taxation is already in place. However, it should be noted that the financial burden for delivering separate programs to manage designated waste streams under these schemes falls upon government and general tax payers, not the producers and consumers of the products. In addition, existing tax revenue allocations for waste management may

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be insufficient to ensure permanent recovery programs for used oils and other designated waste streams in urban, rural and remote communities. As a result, sustainable program financing may necessitate tax-hikes or resource diversion from other community services, both of which are not favoured politically or publicly, especially in the developing world where taxes are often viewed as a social burden. Lastly, as the case with all previous options presented, tax-base funded schemes do not provide a direct financial incentive for consumers to return products to collection points. Deposit-refund schemes Although no examples of product take-back programs for used oils which are funded by deposit-refund schemes were identified, these schemes have been used in some other types of product take-back programs (e.g. beverage containers and used lead acid batteries), and merit discussion due to their potential application to used oils. While the application of deposit-refund schemes may share some similarities with added value service schemes, they do possess some important differences. Deposit-refund schemes generally involve the payment of a surcharge (deposit) on the price of a new product, which is refunded to the consumer (in full or part) when the product or its residual is returned to the point-of-retail or a dedicated collection facility. As a result, this scheme is modelled after the “polluter pays” principle and, unlike the other options presented, provides consumers with a direct financial incentive to return products after use. In some cases, consumers may need to redeem refunds by returning the used product within a specified period of time following the purchase of a new product. Retailer policies may also impose restrictions on claiming refunds (e.g. consumers may be required to provide a proof of deposit that was made at the retailer’s premises to be eligible for a refund). Although the amount of the deposit-refund may vary, generally each component is based on a combination of the avoided environmental costs of improper disposal and any residual economic value that the product may retain after use. In practice, higher return rates are often achieved as deposits and refunds are increased to represent a higher percentage of the product price. However it is equally important to consider the potential adverse impacts that inflated deposits may have on consumer purchasing patterns and society at large, especially in developing countries. The financial and physical responsibility for operating deposit-refund schemes is often delegated to retailers of designated products. Under this approach, vendors are generally required to accept the same brand and type of product that they sell from consumers108 and arrange for pick-up and delivery to collection centres and recycling facilities (often through distributors or service providers). Under these approaches, retailers are expected to meet applicable requirements for the handling and storage of the used products and demonstrate to government that the used products are being sent to licensed final disposition facilities (often through shipping dockets, waybills and/or hazardous waste manifests). Retailers may also be

108 Some deposit-refund schemes may limit the number of products that retailers must collect from customers per visit in an effort to help ensure that product collection burdens are shared in a fair and equitable manner.

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required to report the quantity of new products that they import each year to government. Although vendors may incur additional costs associated with handling returns of designated products, these costs are often offset by the interest earned on deposits, unclaimed deposits109, and/or additional revenue acquired from selling collected products on the secondary market. However, this may not necessarily be the case in remote regions, or countries that do not have domestic end-uses or final disposition options for used oils. In these cases, a non-refundable portion of the deposit could be retained by retailers to compensate their actual expenses110. As the case with added value service schemes, it is also worth mentioning that de-centralized approaches (noted above), which lack a dedicated oversight body to coordinate activities, may lead to difficulties in ensuring that programs are delivered in a consistent fashion and consolidating data to provide an accurate measure of program performance. Alternately, deposit-refund schemes could be applied using a centralized approach (refer to advance recycling fees), in which deposits collected at retail are remitted to a dedicated oversight body that controls the distribution of revenue and coordinates program logistics (e.g. collection, transport, recycling). Under this approach, consumers still claim refunds from retailers, but retailers would have to file a claim with the oversight body to recoup their costs. Centralized approaches can be beneficial in so far that they provide a systematic framework to assure program consistencies, although administratively, they may be more complex (and more costly) to deliver. This approach is most commonly adopted when a non-refundable portion of the deposit (levy) is applied. Regardless of whether a centralized or de-centralized approach is adopted, the private sector will be more inclined to participate in deposit-refund schemes on a voluntary basis if the designated product has residual economic value after use. In most cases however, backdrop legislation will likely be necessary to ensure that private sector responsibilities are carried out in a fair and equitable fashion throughout the country. Tax Exemptions (Subsidies) Tax exemptions or subsidies can be used to stimulate specific activities by exempting them from government-imposed taxes that would otherwise normally apply. For example, exemptions for customs and excise tariffs, import duties, capital taxes and/or sales taxes could be issued to encourage specific capital investments, infrastructure development and technology advancement projects, facility process improvements, program training, and equipment purchases which are assessed to support the ESM of used oils. However, tax exemptions are primarily intended to help build the capital, resources and expertise needed to prepare for program delivery, and, unlike other options, are not applied to raise the resources needed to assure the long-term economic sustainability of product take-back programs. In

109 In some cases, retailers may be permitted to keep all unredeemed deposits to help offset program delivery costs. In other cases, all or a portion of unredeemed deposits may need to be remitted to government. 110 The levy portion of a deposit-refund scheme should be set and allocated carefully to minimize overcompensation of retailers that are located close to final disposition facilities for the used product (and therefore experience smaller transport costs).

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some cases, governments may also make transitional assistance funding available to increase used oil recycling and ensure a sustainable oil recycling industry111. However, government authorities should consider the possibility for opposition to certain subsidies from both public and private stakeholder organizations. For example, private sector enterprises that have already invested in infrastructure improvements to ensure the ESM of used oils will not look favourably upon their competition benefiting from government subsidies, particularly if they themselves are not eligible to receive them. Similarly, subsidies imposed to encourage the use of used oil as a fuel may be opposed by re-refineries/re-processors due to concerns which may arise from the possibility of having to contend reduced feedstocks of used oils. Environmental non-government organizations may also be opposed to subsidies for used oil fuels, particularly if the burning of used oils is not anticipated to be controlled properly by end-users and/or government authorities.

111 For example, the Australian government has been providing transitional assistance funding totaling $34.5 million over 7-years under its Product Stewardship for Oil (PSO) Program. The funding commenced in July 2000 and will be made available until June 2007.

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4 CONCLUSIONS & RECOMMENDATIONS The countries of this region recognize that used oils may pose a threat to human health and the environment if improperly managed. In response, they have demonstrated an ongoing interest to address national deficiencies that may exist with respect to the ESM of used oils (see Section 2) and a willingness to support a regional approach for the ESM of used oils. However, developing countries will require financial support and, in some cases, technical assistance to facilitate the improvements deemed necessary. A regional approach is needed because some Caribbean countries lack end-uses and final disposition options for used oils that are considered to be environmentally sound, and/or do not have sufficient capacity to manage the quantities of domestic used oils generated each year. Also, it may be the case that some SIDS in the Caribbean do not generate sufficient quantities of used oils to make direct consignments with island or mainland countries that do possess ESM-compliant end-uses and final disposition options for used oils economically feasible. In addition to the above, other benefits of a regional approach include:

1. enhanced protection to community health and the environment; 2. greater leveraging power with service providers (larger economies of scale); 3. opportunities for cost-sharing to help drive operational efficiencies; 4. consistencies in program design and delivery; 5. coherent messaging to industry, consumers and the general public; 6. enhanced capacity building in the region; 7. stronger technical expertise through information sharing; 8. enhanced promotion, awareness and enforcement of applicable legislation; 9. persuading ESM of used oils at facilities and operations for which existing

approaches to managing used oils are considered to be inadequate and/or problematic; and

10. improved control over the transboundary movements of used oils.

The Regional Strategy lays out a detailed plan to ensure the ESM of used oils and articulates nine strategic goals to foster success in this area. Although country improvements will largely be driven by their respective governments and the efforts of their National Steering Committees for Managing Used Oils, the importance of countries working together in a cooperative and coordinated manner to encourage regional consistencies in program design and delivery can not be understated. The following recommendations will help to ensure the effective and timely implementation of the Regional Strategy and help to maintain synergies between national and regional used oil initiatives:

1. Engage and secure commitment from potential government, industry and other stakeholders early in the process.

2. Identify champions from both government and industry to motivate, drive and monitor the progress of programs and initiatives for used oils at the national and regional levels.

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3. Multi-stakeholder National and Regional Steering Committees for Managing Used Oils should convene regularly (i.e. once every 2 months for national committees; once every six months for the regional committee) and be limited to a manageable size (e.g. not exceeding 15 participants).

4. Elected chairpersons of National Steering Committees for Managing Used Oils should also be identified as country representatives of the Regional Steering Committee for Managing Used Oils.

5. National and Regional Steering Committees for Managing Used Oils should prepare and interchange annual work plans that are organized to respond to each of the goals and objectives of the Regional Strategy, and clearly identify deadlines, budgets and responsible parties for each activity.

6. Meeting records of National and Regional Steering Committees for Managing Used Oils should be prepared to include an accurate account of attendance, a summary of discussion points, and action items for follow-up.

7. All records, documents, reports and guidelines intended for comment or dissemination to the region and Regional Steering Committee for Managing Used Oils should be made available in the official languages of the participating countries in the region (i.e. English and Spanish).

8. Participants of National and Regional Steering Committees for Managing Used Oils should have strong leadership skills and be able to allocate the time that is necessary to carry out their respective roles and responsibilities.

9. An experienced regional coordinator proficient in the official languages of the participating countries in the region should be elected by the Regional Steering Committee for Managing Used Oils to help coordinate and complete the regional activities under the agreed work plan.

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ANNEXES

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ANNEX A: COUNTRY PARTY STATUS FOR SELECTED INTERNATIONAL TREATIES IN THE WIDER CARIBBEAN REGION Table A1: Country Party Status to the Basel Convention in the Caribbean112

Country 1989 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal

Signature Date Ratified / Acceded

1. Antigua & Barbuda 05-Apr-93 (a) 2. Bahamas 12-Aug-92 (a) 3. Barbados 24-Aug-95 (a) 4. Belize 23-May-97 (a) 5. Cuba 03-Oct-94 (a) 6. Dominica 05-May-98 (a) 7. Dominican Republic 10-Jul-00 (a) 8. France* 22-Mar-89 07-Jan-91 (AA) 9. Grenada 10. Guyana 04-Apr-01 (a) 11. Haiti 22-Mar-89 12. Honduras* 27-Dec-95 (a) 13. Jamaica 23-Jan-03 (a) 14. Netherlands* 22-Mar-89 16-Apr-97 (A) 15. Saint Kitts & Nevis 07-Sep-94 (a) 16. Saint Lucia 09-Dec-93 (a) 17. Saint Vincent & the Grenadines 02-Dec-96 (a) 18. Trinidad & Tobago 18-Feb-94 (a) 19. United Kingdom* 06-Oct-89 07-Feb-94 (R) 20. United States of America* 22-Mar-90 * NOTES: 1. France includes: St. Martin, St. Barthélemy; Guadeloupe; and Martinique

2. Honduras includes: Swan Islands 3. Netherlands includes: Aruba and Netherlands Antillies (Curaçao, Bonaire) 4. United Kingdom includes: Cayman Islands, Anguilla, Montsurrat, and British Virgin Islands 5. United States includes: Puerto Rico including Isla Mona, Navassa Island, and US Virgin Islands

(a) refers to accession

(AA) refers to approval (R) refers to ratification

In the Caribbean Region, Grenada, Haiti, and the USA are currently not Parties to the Basel Convention.

Other Multilateral Agreements for the Wider Caribbean Region include:

International Convention for the Prevention of Pollution from Ships (MARPOL Convention) Cartagena Convention for the Protection and Development of the Marine Environment of the Wider

Caribbean Region Convention on the Conservation of Migratory Species of Wild Animals (CMS) Convention on Biological Diversity (CBD) United Nations Convention on the Law of the Sea (UNCLOS) Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere (CNWH) Inter-American Convention for the Protection and Conservation of Sea Turtles (STC) Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES)

112 Country Party status is current as of 22 May 2006.

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Table A2: Country Party Status in the Caribbean to the MARPOL Convention113

Country 1973/78 International Convention for the Prevention of Pollution from Ships (MARPOL Convention)

Annex I Prevention of Pollution by Oil

Annex II Control of Pollution by Noxious Liquid Substances

Annex III Prevention of Pollution by Harmful Substances in Packaged Form

Annex IV Prevention of Pollution by Sewage from Ships

Annex V Prevention of Pollution by Garbage from Ships

Annex VI114

Prevention of Air Pollution from Ships

1. Antigua & Barbuda Party Party Party Party Party 2. Bahamas Party Party Party Party Party3. Barbados Party Party Party Party Party Party 4. Belize Party Party Party Party Party5. Cuba Party Party Party 6. Dominica Party Party Party Party7. Dominican Republic Party Party Party Party Party 8. France Party Party Party Party Party Party9. Grenada 10. Guyana Party Party Party Party Party11. Haiti 12. Honduras Party Party Party13. Jamaica Party Party Party Party Party 14. Netherlands Party Party Party Party Party15. Saint Kitts & Nevis Party Party Party Party Party Party 16. Saint Lucia Party Party Party Party Party

17. Saint Vincent & the Grenadines Party Party Party Party Party

18. Trinidad & Tobago Party Party Party Party Party19. United Kingdom Party Party Party Party Party Party 20. United States of America Party

Party Party Party

113 Country Party status is current as of 4 August 2006. 114 Annex VI (Protocol of 1997) was adopted at a UN International Maritimes Organization Conference held during 15-26 September 1997.

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Table A3: Country Party Status to the Cartagena Convention in the Caribbean Region115

Country

1983 Cartagena Convention for the Protection and Development of the Marine Environment of the

Wider Caribbean Region

Cartagena Convention 1983 Oil Spills Protocol116

Cartagena Convention 1990 SPAW Protocol117

Cartagena Convention 1999 LBS Protocol118

Signature Date

Ratified /Acceded

Signature Date

Ratified /Acceded

Signature Date

Ratified /Acceded

Signature Date

Ratified / Acceded

1. Antigua & Barbuda 11-Sep-86 11-Sep-86 18-Jan-90 2. Bahamas 3. Barbados 05-Mar-84 28-May-85 5-Mar-84 28-May-85 Nov-02 4. Belize 22-Sep-99 22-Sep-99 5. Cuba 15-Sep-88 15-Sep-88 18-Jan-90 04-Aug-98 6. Dominica 05-Oct-90 5-Oct-90 7. Dominican Republic 24-Nov-98 24-Nov-98 24-Nov-98 03-Aug-00 8. France 24-Mar-83 13-Nov-85 24-Mar-83 13-Nov-85 18-Jan-90 05-Apr-02 06-Oct-999. Grenada 24-Mar-83 17-Aug-87 24-Mar-83 17-Aug-87 10. Guyana 11. Haiti 12. Honduras 24-Mar-83 24-Mar-83 13. Jamaica 24-Mar-83 01-Apr-87 24-Mar-83 1-Apr-87 18-Jan-90 14. Netherlands 24-Mar-83 16-Apr-84 24-Mar-83 16-Apr-84 18-Jan-90 02-Mar-92 06-Oct-9915. Saint Kitts & Nevis 15-Jun-99 16. Saint Lucia 24-Mar-83 20-Nov-84 24-Mar-83 30-Nov-84 18-Jan-90 25-Apr-00

17. Saint Vincent & the Grenadines 11-Jul-90 11-Jul-90 26-Jul-91 26-Jul-91

18. Trinidad & Tobago 24-Jan-86 24-Jan-86 18-Jan-90 10-Aug-99 28-Mar-0319. United Kingdom 24-Mar-83 28-Feb-86 24-Mar-83 28-Feb-86 18-Jan-90 20. United States of America 24-Mar-83 31-Oct-84 24-Mar-83 31-Oct-84 18-Jan-90 16-Apr-03 06-Oct-9921. European Economic

Commission (European Union)

24-Mar-83 24-Mar-83

115 Country Party Status is current as of 4 August 2006. 116 The Protocol concerning Cooperation in Combating Oil Spills in the Wider Caribbean Region entered into force on 11 October 1986. 117 The Protocol concerning Specially Protected Areas and Wildlife entered into force on 11 October 1986. 118 The Protocol concerning Pollution from Land-Based Sources and Activities was adopted on 6 October 1999 but is not yet in force.

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ANNEX B: GEOGRAPHIC LOCATION OF COUNTRIES IN THE REGION THAT COULD POTENTIALLY PARTICIPATE IN THE REGIONAL STRATEGY

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ANNEX C: SUMMARIES OF BASELINE INFORMATION REPORTED BY PILOT COUNTRIES Table C1: Pilot Country Data on the Generation of Used Oils Pilot Country Notes

1. Antigua &Barbuda

No information was provided.

2. Bahamas No information was provided. 3. Belize Most used oils on the island is generated by Belize Electricity Limited, a power generator on the island. 4. Barbados Sources of used oils include motor vehicles, cruise ships and smaller watercraft, motor gas stations, mechanic workshops, car

dealerships, garages, fisheries, manufacturing plants, and power generation stations. Discrepancies regarding the quantity of waste oil generated on the island exist. Barbados National Terminal Company Limited (BNTCL) estimates that 100 to 150 barrels of oily waste is blended with crude oil

monthly (representing 1,200 -1,800 barrels annually). Known sources of used oils (e.g. fisheries, boat owners, buses, etc.) generate 596 barrels of used oils annually, and accounts

for 33 - 55% of the waste oils disposed of at BNTCL. In addition, Barbados National Oil Company Limited (BNOCL) estimates that Esso and Texaco generate 340 barrels annually

for disposal at BNTCL. Approximately 106,145 vehicles are registered for use on the island (90,158 are private cares and hired taxis). An average of 4 M litres of lubricating oils are imported per year, of which an estimated 2.4 M litres per year requires disposal.

5. Cuba A study on the opportunity to collect and recycle used oils revealed that cement factories in Manel (western zone), Siguaney (central zone), and Santiago de Cuba (eastern zone) could burn 5,500 tonnes, 3,500 tonnes and 4,900 tonnes of used oils as fuel per year respectively.

6. Dominica Major sources of used oils include power generation (i.e. Dominica Electricity Services Ltd.), motor vehicles, petroleum filling stations, garages, agri-farming (e.g. banana), and small engine repair and servicing (e.g. outboard motors, lawn mowers, etc.).

The quantity of waste oils associated with motor vehicles; Dominica Electric Services (DOMLEC); storage; and disposal are 125,000 gallons per year; 5,000 gallons per year; 25,000 gallons per year; and 105,000 gallons per year respectively.

7. DominicanRepublic


8. Guyana No information was provided. 9. Jamaica Sources of used oils include motor vehicle fleets, garages, airports, shipping, rail and industry (e.g. bauxite, sugar,

manufacturing, hotel, power generation, and telecommunications). An estimated 9,000 tonnes of used oils are generated each year, representing approximately 60% of the quantity of imported

virgin oils. In 2002, approximately 8.6 million litres of oil was imported. Approximately 8.6 M litres of lubricating oils were imported per year from 2000 to 2002. Of this, 5 M litres required disposal. It is estimated that oily waste constitutes approximately 80% of the total quantity of hazardous waste generated each year in

Jamaica. The volume of used oils generated from the transportation sector is expected to continue increasing readily with the influx of

Table C1: Pilot Country Data on the Generation of Used Oils Pilot Country Notes

used vehicles imported from Asia since 1997. In 2003, 237,572 motor vehicles were certified as fit for roads. All of Jamaica’s petroleum requirements are imported. In 1996, ship-derived oily wastes comprised of oily solid waste (20 tonnes / year), oily sludge (700 m3 / year), waste oil (140 m3

/ year), and oily bilge water (60 m3 / year). 10. St. Kitts & Nevis Sources of used oils include electricity generators, sugar factories, motor vehicle service stations and machine shops. 11. St. Lucia Sources of used oils include electricity generators (largest point generator), land vehicles (e.g. cars, trucks, buses), factories,

and ships and watercrafts. Over 460 m3 of used oils was generated in 2001.

12. St. Vincent & the Grenadines

Lubricating oil is generated from oil changes in vehicles at mechanic shops and gas stations, power stations from generator overhauls and other operations, small generator maintenance (for local businesses and households), and oil changes by boat owners.

Used oils are used for the following applications: lubricating the dumping mechanisms in dump trucks, marking the playing area of football fields, lubricating tire surfaces to fit them onto rims, suppressing dust on dirt and gravel roads, and killing mosquito larvae in stagnant water and latrines and controlling roach populations (by house holders).

13. Trinidad &Tobago

Lubricating oil is generated from transport sector (gas and diesel motor vehicles, air transport, shipping, rail, etc.) and industry (bauxite mining, sugar mills, manufacturing, hotel, power, etc.)

An estimated 9,000 tonnes of used oils are generated each year. This is expected to increase rapidly with the influx of Asian motor vehicles since 1997.

In 2002, 8.6M litres of virgin oil was imported. As a whole, an annual consumption of 15 M litres of lubricating oils exists in Trinidad and Tobago. It is estimated that nearly 4.7 M litres of used oils are likely being discarded each year.

Trinidad and Tobago has the highest vehicle population in the Caribbean. As of August 2000, approximately 350,000 motor vehicles were registered for use in Trinidad and Tobago, with over 60% of them being over 10 years old. It is estimated that each generates approximately 1 gallon of used oils per quarter year.

Trinidad has an array of manufacturing and energy industries that contribute to the generation of used lubricating oils, hydraulic oils, metal working fluids, and insulation and di-electric fluids.

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Table C2: Pilot Country Data on Laws & Policies Applicable to Used Oil Management Pilot Country Notes

1. Antigua &Barbuda


2. Bahamas No information was provided. 3. Belize No information was provided. 4. Barbados There is a need for a manifesting system to help identify the type of oily wastes generated and the final disposition of this

material. 5. Cuba Resolution 87 / 1999 on Hazardous Waste Management bans the import of hazardous wastes and other wastes, places an

obligation on generators to manage hazardous wastes, requires hazardous waste management plans, and provides the authority under which compulsory environmental licenses are issued to generators.

The Decree Law 200 / 1999 regarding the Contravention of Environmental Matters recognizes the following as activities as illegal: managing hazardous wastes outside of the site of generation without a license; not submitting information relative to hazardous waste inventories; non-compliance with hazardous waste management plans, terms and conditions; and not providing notification of an accident within 24-hours of its occurrence.

There is a need for competent authorities to implement a domestic policy for the collection of used oils and to formulate standards and restrictions for consumers to encourage the return of higher quality used oils.

There is a need to implement policies aimed at improving the collection of used oils by CUBAPETROLEO Union Trading companies.

6. Dominica No information was provided. 7. Dominican

Republic No information was provided.

8. Guyana No information was provided. 9. Jamaica Inadequate levels of penalties, monitoring and enforcement exists.

The National Solid Waste Management Act (NSWMA), 2001 is jointly administered by the Ministry of Local Government and Works, the National Works Agency and the National Solid Waste Management Agency. The Act provides the authority to protect human health and the environment from wastes, including liquid and hazardous wastes. Waste management facilities and operations are also licensed under this Act. Permits are required to export hazardous wastes from or through any area within Jamaica’s jurisdiction.

The National Resources (Hazardous Waste)(Control of Transboundary Movement) Regulations, 2002 and NRCA Permit and Licensing Regulations, 1996 are jointly administered by the Ministry of land and Environment and the National Environment and Planning Agency. Jamaica maintains a policy of not allowing the import of hazardous wastes into the island.

Energy policies are administered by the Ministry of Commerce, Science and Technology. Draft national policies on environmental management systems and for the management of hazardous substances and wastes

also exist. 10. St. Kitts & Nevis No information was provided.

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Table C2: Pilot Country Data on Laws & Policies Applicable to Used Oil Management Pilot Country Notes

11. St. Lucia National standards are needed to specify quality guidelines (e.g. acceptable water and impurity content) for used oils end-uses National standards are also needed to guide the transportation of used oil, including the spill management, tracking and data

collection of used oils. Need to establish operational standards for equipment utilized to process used oils. Uniform waste management legislation encourages the reuse of waste products (e.g. burning of used oils as a supplementary

fuel). No standards exist regarding the processing of used oils generated by large ships (some has large water content and contain

many impurities). No requirements for personal safety and protective equipment exist for workers involved in used oils collection, transportation,

recycling or treatment. The St. Lucia Solid Waste Management Authority and ship agents must receive prior informed notice before used oils are

accepted from large ships. The Waste Management Act contains authority to establish guidance of the management of used oils. St. Lucia has a National Oil Spill Committee (NEMO). A draft National Waste Oil Strategy exists. The Draft Marine Pollution Bill will help to enforce requirements of the Basel Convention. Burning used oils as a supplementary fuel harmonizes with the uniform waste management legislation, which encourages the

reuse of waste products. 12. St. Vincent & the

Grenadines CWSA is currently working on a formal policy for used oil management in St. Vincent & the Grenadines.


No national laws exist to require the collection and recycling of used oils. The revised (2005) National Environmental Policy provides a broad framework that promotes the 4Rs (i.e. reduce, reuse,

recycle, recovery). Inadequate levels of penalties, monitoring and enforcement. National Solid Waste Management Act (2001) encourages ESM and requires waste operators and collectors to be licensed. Natural Resources Regulations (2002) controls hazardous wastes and transboundary movement of hazardous wastes. Current policy does not allow import of to island. Draft National Policy and Strategy on Environmental management Systems promotes EMS and greening operations. Draft Policy for the Management of Hazardous Substances and Waste.

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Table C3: Pilot Country Data on Existing Approaches to Used Oil Management Pilot Country Notes

1. Antigua &Barbuda

The West Indies Oil Company (WIOC) carried out a project to safely dispose of waste oils and oily sludges from power generation stations, service stations, hotels, auto dealers, and other generators using a biopile facility in Antigua. The tipping fee at this facility is approximately $0.75 USD per gallon used oils.

The Antigua biopile facility located at WIOC consists of multiple bays, each with a dimension of 100’ x 200’ x 7’ deep. This facility disposed of 300,000 gallons, 390,000 gallons and 275,000 gallons of waste oil in 2001, 2002 and 2003 respectively. At least 90% of this waste was generated in Antigua (mainly from power generating plants). The remaining waste (less than 10%) was waste oil collected from cruise ships. Only lubricating oils, tank bottoms and separator sludges are managed at this facility.

2. Bahamas No information was provided. 3. Belize Crude dumping and improper storage of used oils are ongoing problems. Used oils have also been used for herbicides,

insecticides and pesticides, coating molds for shaping polyurethane products, hydraulic systems in dump trucks, brick manufacturing, dust suppression and to treat mange on dogs.

Used oils storage facilities exist at Belize Electricity Limited. The Shell Terminal also offers customers a used oils storage service, however plans are in place to phase out this service.

Options for the reuse of used oils on the island include Used oils could potentially be burned as a furnace fuel at four small aluminium smelting operations (that manufacture frying

pans, pots, waffle irons, etc.) or as a boiler fuel in the sugar and citrus industry. However approvals must first be obtained from the Belize Department of Environment.

4. Barbados The collection and transport of oily waste for disposal at BNTCL is performed by Machinery & Allied Engineering Services (MAES) Limited. This is currently the only company collecting used oils for disposal at this facility. MAES Limited does not maintain records of the quantities of oily wastes collected from generators.

Disposal options for used oils include the Barbados National Terminal Company Limited (BNTCL), which blends waste oils with crude oil for export to refineries, and Arawak Cement Company Limited (ACCL), which burns the waste oil as a fuel at a high temperature (1450°C).

Foreseen problems include the management of oily rags and filters. 5. Cuba Used oils have mainly been used for fuels in clinker kilns in the cement industry. Other minor end-uses include the use of used

oils as fuel in boilers in the sugar industry and for general maintenance of machinery equipment. 6. Dominica There is no organized system of the management of used oils.

Dominica is being promoted as an eco-tourism destination and the proper disposal of used oils are critical to environmental protection and conservation.

Limited storage capacities for used oils exist at service stations. End-uses for used oils include re-use to protect metal parts from corrosion, lubricating moving parts in small engines, protecting

wood from termite infestation and larvicidal control of mosquitoes. There is a need to increase the storage capacity for used oils on the island. There is also a need to explore the usage of used oils as a bunker fuel for the generation of electricity.

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7. DominicanRepublic


8. Guyana No information was provided. 9. Jamaica No dedicated facilities for the safe storage and disposal of used oils exist.

Currently, the final disposition of used oils includes use as a supplementary fuel feedstock in industries; unstructured industry reuse (e.g. road works); entrepreneurial activities (e.g. pot firing, fuel blending, reused lubricants); unstructured casual applications and dumping.

A pilot project is currently underway to route used oils to the island-based Caribbean Cement Company Limited for high temperature burning as a fuel.

There is inadequate quality control to ensure that used oils are appropriate for resource recovery end-uses. A low level of product stewardship exists throughout the island. Used oils are currently burned as a supplementary fuel by Caribbean Cement Co. Ltd. As of 1994, Jamaica power generator (JPSCo) retired 5,781 transformers. JSPSCo.’s environmental policy indicates that PCB-

containing transformers will be scrapped and shipped to France for disposal. 10. St. Kitts & Nevis St. Kitts and Nevis is beginning to collect used oils at landfill sites.

Returned used oils are transported and stored at a 50,000 imperial gallon storage tank that is operated by the St. Kitts Solid Waste Management Corporation (SWMC). This facility has been accepting used oils for storage at a cost of $2.00 USD / gallon since May 2003. The facility services two main customers, namely Royal Utilities (the power generator for the Royal St. Kitts Marrot Resort) and the St. Kitts, Nevis, Anguilla Trading and Development Company Limited (TDC).

As of 2004, 2,703 gallons of used oils has been collected at this facility (located at the Conaree Landfill facility). The government will make fuel supplier contracts for the island’s power plant contingent upon assuming the responsibility for recycling the used oils when this storage tank is full.

Many potential customers (e.g. mechanics) have expressed reservations about returning used oils and still having to pay for the service. SWMC is exploring the possibility of getting a vehicle to collect used oils from mechanic shops on a bi-weekly or monthly basis.

11. St. Lucia Burning of used oils as a supplementary fuel is deemed to be the most cost efficient recycling option, generating savings on fuel costs for participating industries. The cost to the original consumer (generator) is also considered to be negligible. However, potential environmental concerns (e.g. air quality) must also be taken into account.

End-users to burn used oils as a fuel already exist on the island, and they are willing to institute improvements where necessary.

Used oils are used as a supplementary fuel for boilers at a linen factory and a distillery, and for a kiln at a clay products factory. Used oils received from large cruise ships is used as supplementary fuel. Prior notice requesting discharge is given to ship agents and the St. Lucia Solid Waste Management Authority.

Burning of used oils as a supplementary fuel harmonizes with the uniform waste management legislation, which encourages the reuse of waste products. However, ash and sludge waste from these processes is not adequately managed. In addition,

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the environmental impact of these processes on air quality is not known. 40 storage containers for used oils with a capacity of 1,200 litres each were procured under the Organization of Eastern

Caribbean State (OECS) Solid and Ship Generated Waste Management Project which will be deployed at island-wide garages, petrol stations, fire stations, hotels and large fast food restaurants to facilitate used oils collection

Other minor uses include wood preservatives, suppressants for mosquitoes and vermin, treatment of livestock for parasite control, lubricating moulds and formwork for concrete, and marking sports fields.

Crude dumping of used oils are very prevalent in St. Lucia, leading to pollution of surface water, groundwater contamination, and soil contamination (including beach and seabed contamination).

St. Lucia procured 40 used oils storage containers (each 1,200 litres in size) under the Organization for Eastern Caribbean States (OECS) solid and ship generated waste management project. Containers were deployed at service stations, garages, fire stations, hotels and large fast food restaurants.

Large storage tanks are also used to filter impurities. One user collects used oils from the island and cruise ships. Two other private sector transporters also periodically collect used

oils. A large proportion of used oils come from cruise ships. Need to explore contingency plans in the event that existing end-use options for used oils are discontinued. Components needed for a recycling strategy for used oils include: collection and storage; transportation; processing; disposal

of impurities; health and safety; spill prevention and management; education and awareness; and legislation and policy. 12. St. Vincent & the

Grenadines Used oil from VINLEC, the island power generated, is collected in drums and sent to Trinidad for processing. Approximately

5,400 gallons of used oil are shipped from the Shell facility at VINLEC to Trinidad every quarter year. Used oil generated from motor oil changes at Shell facilities is collected in storage tanks. At one facility, it takes approximately

2 years to fill a 135 ft3 storage tank with used oils. Used oil is subsequently pumped into drums and sent to Trinidad. Used oils are also collected in gallon containers from consumers.

Mechanic shops also store used oils in drums and/or plastic buckets and metal containers on the properly, and typically do not have a disposal strategy in place.

Used oils have also been disposed on vacant lots, and in open drums and waterways. 13. Trinidad &

Tobago Oil Mop Services re-processes used oils for the companies National Petroleum and Petrotrin. A privately-operated bioremediation site exist on the La Brea Industrial Estate. Trinidad Cement Limited has been identified as a possible site for the use of used oils as a fuel. Dumping a problem. No dedicated facilities for the safe storage and disposal of used oils. Dispersed informal vehicle servicing shops. Use as supplementary fuel feedstock, dust suppressant, pot firing, fuel blending, and reuse. Inadequate quality control. Used oils are currently burned as a supplementary fuel by Trinidad Cement Ltd.

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Table C4: Pilot Country Data on Public Awareness and Education regarding Used Oils Pilot Country Notes

1. Antigua &Barbuda


2. Bahamas No information was provided. 3. Belize No information was provided. 4. Barbados Public awareness programs are needed to discourage fishermen from disposing waste oil at sea and leaving buckets of waste

oil laying around. It is necessary to improve the level of knowledge of personnel handling used oils on a regular basis with respect to the

quantities of used oils generated, where and how the used oils are disposed, and the on-site storage capacity for used oils. The used oil management plan should address spill clean up. Incentive systems are needed to discourage crude dumping of oily wastes.

5. Cuba No information was provided. 6. Dominica No information was provided. 7. Dominican


8. Guyana No information was provided. 9. Jamaica Improperly managed, used oils may contribute to fire hazards, vegetation damage, water contamination, and health and safety

problems. Need to elevate public sensitivities and political focus on used oil management issues with an emphasis on environmental,

health and energy. Need to consider financial intervention options for the ESM of land-based and ship generated used oils. Consumers are price sensitive to levies, taxes and other financial intervention options. ESM is difficult to monitor at the many informal vehicle servicing shops dispersed throughout the island. In some cases, a low company or institutional priority has been placed on the ESM of used oils.

10. St. Kitts & Nevis No information was provided. 11. St. Lucia Public education is needed to ensure participation in use oil collection programs. The location and operating hours of used oils

collection centers should be clearly posted and communicated. Health and safety concerns exist regarding used oil management. It is recommended that handlers wear personal protective

equipment, including a helmet or cloth cap; safety glasses, goggles or a face shield; dust or fume masks; nitrile rubber or neoprene gloves; overalls; nitrile rubber or neoprene aprons; and strong rubber or neoprene boots.

Both industry and the general public needs to be informed that used oils should not be mixed with other substances. All workers in the used oils industry need health and safety training. All drivers should be trained on operating procedures for tanker work. Need to secure support from politicians and other key stakeholders. Cultural habits and practices coupled with the lack of education, and limited financing and improper allocation of human

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Table C4: Pilot Country Data on Public Awareness and Education regarding Used Oils Pilot Country Notes

resources to develop systems continue to pose challenges for the ESM of used oils. Need to institute training and awareness programs for generators and handlers regarding spill management and response. Need to ensure that used oils are tested prior to collection and burning as a fuel. Need to institute economic instruments to encourage public / private sector participation. Need to assess the impact of burning used oils as a fuel on the air quality at facilities. Need to adopt contingency systems in the event that domestic final disposition options for used oils are temporarily or

permanently discontinued. 12. St. Vincent & the

Grenadines No information was provided.


Public compliance in adhering to ESM practices is a problem, therefore some form of economic incentive and public education and awareness campaign is needed.

Consumers are sensitive to price increases (e.g. product levies). ESM of used oils are a low priority for many companies/institutions. Insufficient sensitivity regarding potential harm.

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Table C5: Pilot Country Data on Environment and Health Issues Related to Used Oils Pilot Country Notes

1. Antigua &Barbuda


2. Bahamas No information was provided. 3. Belize No information was provided. 4. Barbados No information was provided. 5. Cuba No information was provided. 6. Dominica No information was provided. 7. Dominican


8. Guyana No information was provided. 9. Jamaica No information was provided. 10. St. Kitts & Nevis No information was provided. 11. St. Lucia Crude dumping contributes to pollution of ground and surface water, and contamination of soil, beaches and the seabed.

Sludge from used oils burning at industrial furnaces and boilers is not adequately managed. The impact of burning used oils on air quality is unknown. Need to test used oils prior to collection and burning. Workers are not required to wear personal protective equipment during used oils storage, handling, transport or treatment.

12. St. Vincent & the Grenadines



Fire hazards, vegetation damage, water contamination, health and safety implications.

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ANNEX D: VESSEL MOVEMENTS IN THE WIDER CARIBBEAN REGION119

119 Based on information contained in the 1996 International Maritime Organization Report on Vessel Movements in the Wider Caribbean. Wider Caribbean Initiative on Ship-generated Wastes.

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Figure D1: General Cargo & Miscellaneous Traffic in the Wider Caribbean Region (1996 data)

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Figure D2: Passenger Vessel Routes in the Wider Caribbean Region (1996 data)

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Figure D3: Crude Oil Traffic in the Wider Caribbean Region (1996 data)

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ANNEX E: SECONDARY TREATMENT OPTIONS FOR OIL-WATER SEPARATION Table E1: Description of Secondary Treatment Options for Oil-Water Separation

Type of Secondary Treatment

Description Water Phase Effluent Notes

Coagulation &

Flocculation

(followed by Air Flotation)

Separate mixing tanks are dosed with chemicals that cause either the coagulation or flocculation of oil.

Oil emulsions are broken in the first tank via coagulants (i.e. Iron/aluminium salts, or charged polymers).

Coagulated oil particles are fed into the second mixing tank and exposed to flocculants which agglomerate oil making it easier to separate from water.

Air flotation units augment the flocculation process by using bubbled air and a skimmer to facilitate oil separation.

20 - 40 ppm The separated oil phase has a high water content and must be followed by centrifuge treatment prior to reuse (e.g. burning as a fuel).

Filter Units

Filters remove oil from wastewater primarily through the processes of adsorption and coalescence.

Two types of filters are common: precoat filters (that often use sawdust or diatomaceous earth as the filter medium), and coalescence filters (that often use sand, other granulated material, or wire mesh as the filter medium).

5 - 20 ppm Fouling of filters will occur over time, leading to an increasing pressure drop over time, and necessitating backwashing.

Use of flocculating chemicals contribute to lower concentrations of water phase effluent (5 ppm)

Precoat filters are recommended since coalescence filters do not treat oil emulsions well.

Hydroclones

Involves the centrifugal separation of water and oil based on the differing densities of these liquids.

Pressurized wastewater is tangentially fed into the large diameter end of a static bottle-shaped tube.

As wastewater swirls within the tube, centrifugal force causes water (the denser liquid) to concentrate along the outer circumference of the tube while oil collects near the core.

The motion of the liquids creates a vortex that causes the oil liquid core to flow in an opposite direction to the outer water shell.

Oil is collected at the wide end of the tube, while water is collected at the narrow end of the tube.

5 - 15 ppm Traditionally a costly technology High wear on pumps Problems handling stable emulsions Potential to replace air flotation units and

filter units

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Table E1: Description of Secondary Treatment Options for Oil-Water Separation

Type of Secondary Treatment

Description Water Phase Effluent Notes

Centrifuges

Also involves the centrifugal separation of water and oil based on the differing densities of these liquids.

Unlike hydroclones, the centrifuge is mechanically rotated to allow for the separation of water, sediment and oil phases at different outlets.

Water effluent is recycled to primary treatment processes (i.e. gravity separation)

Unlike hydroclones, centrifuges are capable of separating water, sediment and oil phases simultaneously.

Often used for de-watering and de-sludging oil at port reception facilities.

Molecular Coalescence

Oil-Water Separator

The oil content of a liquid is trapped behind a weir where it is coagulated and separated using a tilted disk skimmer.

A biologically activated “bio-pack” is placed downstream of the weir to degrade oil that may be adsorbed or adsorbed to suspended solids located in the water effluent.

1 - 5 ppm The water content of separated oil is <10% and often <1%.

The bio-pack may be destroyed by some toxic chemicals or lack of oxygen.

Membrane Separation

Liquids are passed through selective (semi-permeable) membranes under pressure.

Two types of crossflow membranes are commonplace: ultrafiltration (UF) membranes and microfiltration (MF) membranes.

The approximate lifespan of polymetric membranes and ceramic membranes are 1 year and 3 - 5 years respectively.

2 - 15 ppm UF membranes are more commonly used for oil-water separation because they have a smaller porosity than MF membranes and are able to operate at higher pressures.

Larger pumps are required than other treatment processes.

Membrane systems may require frequent cleaning.

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ANNEX E: LIST OF ABBREVIATIONS

BCRC Basel Convention Regional Center

BCRC – CARIBBEAN BCRC – Caribbean (central office in Trinidad & Tobago)

CAF Andean Development Corporation

CARICOM Caribbean Community

CARIRI Caribbean Research Institute (former administrator of BCRC-CARIBBEAN)

CBD Convention on Biological Diversity

CCAD Central American Commission for Environment and Development

CDB Caribbean Development Bank

CITES Convention on International Trade in Endangered Species of Wild Flora and Fauna

CMS Convention on the Conservation of Migratory Species of Wild Animals

CNWH Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere

COP Conference of the Parties

ESM Environmentally Sound Management

EU European Union

GEF Global Environmental Facility

GRULAC The Group of Latin American and Caribbean Countries

IBRD International Bank for Reconstruction and Development

IMO International Maritime Organization

MARPOL Convention International Convention for the Prevention of Pollution from Ships

NCPCs National Cleaner Production Centers

NGO Non-Governmental Organization

OECS Organization of Eastern Caribbean States

OEWG Open Ended Working Group

PAHO Pan American Health Organization

SBC Secretariat of the Basel Convention

SIDS Small Island Developing States

STC Inter-American Convention for the Protection and Conservation of Sea Turtles

UNCLOS United Nations Convention on the Law of the Sea

UNCTAD United Nations Conference on Trade and Development

UNDP United Nations Development Program

UNEP United Nations Environment Program

US EPA United States Environmental Protection Agency

UWI The University of the West Indies

WCISW Wider Caribbean Initiative for Ship-generated Waste

WHO World Health Organization

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ANNEX F: USEFUL SOURCES OF INFORMATION GUIDANCE 1. Basel Technical Guidelines on Waste Oils from Petroleum Origins and Sources (Y8).

www.basel.int. 2. Basel Technical Guidelines on Used oils Re-refining or Other Reuses of Previously Used Oil (R9).

www.basel.int. 3. International Maritime Organization. Code of Conduct for the Prevention of Pollution from Small

Ships in Marinas and Anchorages in the Caribbean Region. 4. International Maritime Organization. Guide to Ports and Marinas Requiring Waste Reception

Facilities. (WCISW Report No. 3. 5. International Maritime Organization, 1999. Comprehensive Manual on Port Reception Facilities.

IMO-597E. 6. International Maritime Organization, 1997. Regional Waste Management Strategy for Port

Reception Facilities in the Wider Caribbean. Wider Caribbean Initiative on Ship-generated Wastes Project. Corbett & Holt, L.L.C.

7. International Maritime Organization, 1996. Strategy and Action Plan for Source Reduction Recycling and Recovery of Ship-generated Waste. Wider Caribbean Initiative on Ship-generated Wastes Report No. 4.

8. Organization of Eastern Caribbean States - Environment and Sustainable Development Unit, 2002. Organization of Eastern Caribbean States Strategy on the Management of Used Oil. Contract No. 2002.028/GETF.

BACKGROUND INFORMATION 1. International Maritime Organization, 1996. Report on Vessel Movements in the Wider Caribbean.

Wider Caribbean Initiative on Ship-generated Wastes. 2. Proceedings of the Regional Workshop on the Assessment of the Environmentally Sound

Management of Used Oils in the Caribbean (St. Anns, Trinidad and Tobago, 21 - 22 March 2006) 3. Proceedings of the Regional Workshop on the Assessment of the Environmentally Sound

Management of Used Oils in the Caribbean (Port-of-Spain, Trinidad and Tobago, 15 - 17 June 2004)

INTERNATIONAL CONVENTIONS 1. 1989 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and

their Disposal (Basel Convention) 2. 1973/78 International Convention for the Prevention of Pollution from Ships (MARPOL

Convention) 3. 1983 Cartagena Convention for the Protection and Development of the Marine Environment of the

Wider Caribbean Region (Cartagena Convention) USEFUL WEB SITES

Organization Web Address 1. Secretariat of Basel Convention (SBC) www.basel.int 2. International Maritime Organizations www.imo.org 3. Caribbean Environment Programme www.cep.unep.org

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Documents

Regional Strategy for ESM of ULAB - UN Environment · REGIONAL STRATEGY FOR THE ENVIRONMENTALLY SOUND ... National Office of Pollution Prevention ... Regional Centre in Trinidad and