- Robin des Bois - http://www.robindesbois.org/en -

Robin des Bois’ viewpoint on the importation of HCB from Australia to France

Robin des Bois was consulted by Orica over the possible treatment, at Trédi’s incinerator at Salaise-sur-Sanne (France), of HCB waste stockpiled, since 1991, in Botany situated 8km from Sydney. Two representatives from Robin des Bois gathered information on site at the end of 2013 in order to understand why an industrial firm, located in Australia, an economically developed country, would want to export waste 17,000km away.

It was noted that the 13,800 tonnes of waste is stockpiled in a highly urbanised area. The Botany stockpile is exposed to natural and industrial external threats. The HCB concentration of the stockpile ranges from 0.003% to 89%. Certain waste requires repackaging every 4-5 years. Repackaging operations increase the total weight of the waste by 2.0% on average, per annum. Orica’s stockpile is historical and HCB is no longer produced in Australia.

It is urgent to launch the destruction of the stockpile. No existing, or experimental installations in Australia fill necessary criteria for the protection of workers and the environment. Considering the heterogeneity of consistencies of the waste Robin des Bois believes that any pre-treatment, an additional risks for workers, must be avoided. Consequently, it is advisable to treat every container ‘as is’ through a direct channel. Trédi’s Salaise-sur-Sanne is one of the few incinerators in the world which corresponds to this constraint.

Orica has treated 45,000m3 of HCB contaminated soil in situ. Thermal desorption used to treat the contaminated soil is not adaptable to treat the other waste.

The Non Governmental Organizations (NGOs) opposed to earlier export attempts (Germany, in 2006 and Denmark, in 2008) have done nothing since to find an Australian solution.

The industrial site at Salaise-sur-Sanne should not be named a worldwide waste vacuum: waste imported from outside of the European Union amounts to 2% of all waste treated in 2012 and 1% in 2013.

Robin des Bois’ main recommandations are:
– A feasibility test of treatment can be carried out at Salaise-sur-Sanne on a reduced quantity (around 100 tonnes). This test will be in order for State departments, neighbours, NGOs and the industrial stakeholders to cross-check the security logistics and the atmospheric and liquid effluents and solid residues during the treatment. The proper implementation of these different stages will determine any future demands for export.
– During the trial run, if the importation permits are approved by the appropriate authorities, Trédi Salaise must put in place a specific protocol for monitoring discharges and residues. The results must be communicated to all interested parties.
– Vigilance on administrative, insurance and logistical levels concerning the vessels and the containers must guide the maritime transport. The containers must be new and equipped with a detection beacon. The maritime transport company must have a detailed emergency plan and must have the financial and operational means to put it in place. The vessels should not have been detained for deficiencies and to avoid a dilution of responsibility in the case of an accident must be operated by the ship-owner. Orica has accepted these recommendations and the proposed plan has been altered and improved.
– The export of liquid waste is not an option. At the same time, Australia should find a home-based solution to treat the 250 tonnes of liquid waste.
– If the first trial run is validated, the deliveries following must be of the similar volume to avoid any storage problems in the receiving country. Orica has accepted the principle to treat the waste over numerous years.

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Note to editors:

HCB, hexachlorobenzene
, is an organochlorine compound classified by the International Agency for Research on Cancer as 2B “probably carcinogenic to humans” (WHO). The major sources of exposure of HCB to humans are ingestion and skin contact. In the 1950s, in Turkey, thousands of people ingested HCB-treated seed grain which caused skin lesions, neurological impairments, metabolic disorders and caused the death of babies under the age of one or whose mother consumed the contaminated wheat. These events of porphyria cutanea tarda were observed following an estimated ingestion of 50 to 200 mg/day for numerous months. Short-term high exposures can lead to kidney and liver damage, central nervous system excitation and seizures, circulatory collapse, and respiratory depression. Hexachlorobenzene is chemically stable, environmentally persistent and resistant to degradation in the environment. It is bioaccumulable, particularly after prolonged or frequent exposure. It builds up in terrestrial and marine food chains, in the fatty tissue of fish and sea mammals and also in lichens, wheat, grasses and vegetables. Traces have been found in Arctic and Antarctic sediments

HCB was produced for industrial applications (pyrotechnics, synthetic rubber, the aluminum industry, as a disinfectant in soap, etc.) and agricultural uses (fungicide from the 1940s to the 1970s). The production and marketing of HCB were banned in France in 1988 and in Europe in 1993.
HCB is also an inevitable by-product of the manufacture of chlorinated solvents, vinyl chloride, chlorinated aromatic compounds and chlorinated pesticides.

Sources: World Health Organization (WHO), International Agency for Research on Cancer (IARC), US Environmental Protection Agency (USEPA) and French Institute for Public Health Surveillance (InVS).

Robin des Bois is a Non Governmental Organization based in Paris, France founded in 1985 with an international orientation. Among other subjects, the NGO is a specialist in contaminated sites on land and in aquatic environments, post-disaster waste, the treatment of waste and maritime safety.