ILMC Risk Reduction Activities

ILMC has explored the utility of different approaches for the establishment of national risk management programs for lead through the implementation of Pilot Programs. Pilot Programs are constructed as multi-stakeholder consultative processes that identify and promote risk reduction objectives via regulatory and non-regulatory mechanisms. Such programs are designed as "demonstration projects" and serve as models for the environmental improvements that might be achieved under different cultural and socioeconomic circumstances. The "lessons learned" from individual Pilot Programs further serve as the basis for the development of systemic approaches to capacity building that will promote risk reduction in multiple countries within a given region.

Countries in Southeast Asia have been experiencing rapid growth and rising demand for lead, with consumption demands being met principally through secondary lead production. Demand for lead has traditionally exceeded that available from domestic recycling efforts by approximately 40% and the secondary lead industry has met demands by importing used lead acid batteries for recycling. However, the Basel Convention has impacted upon the availability of feed materials for the Southeast Asian secondary industry. Thus, ILMC has been working with UNCTAD, the United Nations Development Program, the Philippine Department of Trade and Industry, and local industry to assist in the development of proactive strategies for adjusting to Basel-related alterations in material flow while at the same time ensuring adequate environmental performance and occupational safety.

Early ILMC activities in the Philippines focused upon working with Philippine Recyclers, Inc. (PRI) a large licensed recycling facility just outside of Manila. ILMC conducted environmental assessments of the PRI facility in September of 1997 and began working with the company to establish a process of continuous environmental improvement. Following consultations with ILMC staff, numerous ILMC visits to the Philippines, and visits of PRI staff to secondary facilities in OECD countries, technical and management changes were effected at the facility to significantly reduce environmental emissions and levels of occupational exposure. The Environmental Management Bureau of the Philippines served to verify the improvements made by the facility. Among the many achievements of PRI has been the successful implementation of a "Return Your Batteries" Program that was launched as a means of recovering approximately 36,000 tons of scrap batteries generated each year in the Philippines. The Program encouraged motorists to return their used batteries when a new one was purchased through a series of financial incentives. Using the sales networks for new batteries, the Program succeeded in capturing 750 tons of scrap batteries per month in its first year, a 100% increase over the collection rate the previous year. The collection rate for used batteries has grown steadily at a rate of 500 metric tons per year.

PRI also committed to the implementation of environmental management systems based upon the ISO 14001 framework. Although the company already had a formal quality management system, and had most of the components in place to meet the standards of ISO 14001, much additional work was required. Several specialist teams were commissioned to work on the project, with almost half of the PRI employees ultimately developing direct involvement. This effort resulted in the facility achieving ISO 14001 accreditation in late 1999. PRI was the first heavy industry in the country to achieve ISO accreditation and is only the third battery recycling facility in the world to do so. Achievement of accreditation was particularly challenging in the Philippines because, unlike most countries, the Philippines lacks facilities designated for the disposal of toxic and hazardous waste. PRI, working with ILMC, was able to develop the means by which hazardous waste generation was essentially eliminated and existing stocks of waste materials were converted into inert non-hazardous materials. Among the innovations employed was the development of a process to segregate ebonite case material from battery plate separators. This process should enable PRI to reduce its present stockpile of hard rubber waste by 70%. The remaining waste material, composed principally of paper, PVC and plastic separators, is being further sorted and retreated. PRI plans to sell the ebonite as a secondary fuel and to use portions of this waste flow as a reducing agent in their furnaces for secondary lead production. A formal ceremony in recognition of ISO 14001 certification was held in February 2000.

ILMC continues to work with the staff of PRI to ensure that a process of continuous environmental improvement is maintained. PRI has also sought involvement in other ILMC activities. For example, the United Nations Environment Programme and ILMC recently convened an Environmental Technology Assessment (EnTA) Workshop in Manila for which the PRI experience served as a case study. PRI hosted visits to their facility so that the EnTA delegates could inspect first hand the technical improvements made at the facility and to learn more about the active community outreach programs that had been established by the company to provide medical services to the local population.

The improvements made by PRI marked the maturation of the first phase of the Philippines Pilot Program. Under the Memorandum of Understanding between ILMC, UNCTAD and the Philippines government, efforts are now moving to resolve issues associated with the activities of unlicensed small battery recyclers, battery reconditioners and cottage smelters. The activities of the informal sector constitute a significant source of general population exposure to lead. ILMC has been working with the Philippine government and UNCTAD in the design of economic, technical and regulatory instruments that seek to incorporate the "informal sector" into an organized infrastructure for the collection of lead acid batteries for recycling by licensed facilities. The technical and socioeconomic factors that promote the activities of the informal sector have been analyzed in a series of papers prepared to guide the deliberations of an expert multi-stakeholder panel. The panel had initially been scheduled to meet in July 2000, but this meeting has been postponed until November because several members of the panel were indisposed.

Changes made to date in the Philippines, as well as improvements yet to come, provide a model for change in the ASEAN region. Multiple countries now wish to address issues associated with growing quantities of waste battery scrap and recognize the need to recover this waste for use by their domestic industry sectors.

Program activities in Mexico are broadly based and target multiple lead producing and using industry sectors. The program was initiated under an agreement between the Instituto Nacionale de Ecologica (INE; Environmental Agency of Mexico), Camera Minera de Mexico (Mexico Chamber of Mines) and the ILMC. In accordance with initial working agreements established in March of 1998, the parties identified a demonstration project to serve as a model for the environmental performance assessments and improvement options available to different sectors of the industry in Mexico. An environmental audit was conducted at a lead oxide production facility representative of the older technology in place at some facilities in Mexico. The action plan being implemented at this facility will improve its environmental performance and generate a generic "Safe Operating Procedures Manual" useful to other industry sectors working with lead.

Principle aspects of the program in Mexico have been adapted, at the request of the government, to address several broad and pervasive environmental issues confronting the country. For centuries Mexico has been one of the most important mining countries in the world. The contribution of this industrial sector to the economic and urban development of the country has been significant, particularly during the period of rapid industrialization between 1950 and 1970. Although Mexico has been among the leading world producers of non-ferrous metals, the environmental impacts of mining activities in Mexico have never been systematically assessed. However, public concern regarding occupational health, water and air pollution and general population exposures associated with smelting operations has been increasing. Unfortunately, efforts to address these concerns have been complicated by the heterogeneous nature of minerals in different regions of Mexico, the different technologies that had been employed to extract minerals, and the diverse range of social conditions and ecosystems at sites of contamination. This has posed formidable challenges to efforts to assess and manage the risks from mining and smelting waste materials.

ILMC involvement in these broader issues began at a two-day workshop in Mexico City in November 1999 concerning "Risk Assessment, Management and Communications Related to Mining and Metallurgical Wastes". The Workshop was sponsored by the INE, the National Environmental Research and Training Center, the Japanese International Cooperation Agency, and the ILMC. ILMC staff and technical experts from the ILMC membership were active participants in the Workshop. As a result of the Workshop, the government decided to embark upon a program to control wastes associated with mining and metallurgical processes. This was in turn followed by a request to ILMC to provide assistance on issues associated with site remediation at abandoned mine and smelter sites.

In June 2000 ILMC submitted a preliminary proposal for a project to prepare a remediation manual to guide cleanup efforts at abandoned lead mines, smelters and secondary facilities. ILMC proposed preparation of a manual to detail the most cost effective methods for minimizing general population lead exposure, with a specific early focus upon the remediation of soil at an abandoned lead smelter in Tijuana. Following receipt of a positive response from the government to ILMC's preliminary proposal, ILMC submitted a detailed plan for a project to prepare "remediation guidelines for abandoned lead mines, smelters and secondary plants". The project proposes to define the scientific principles and technical guidelines by which site assessments should be conducted, remediation strategies implemented, and adequate follow-up measures undertaken so as to ensure the efficacy of remediation efforts. Government approval of this project proposal is pending.

The first steps of the proposed project entail assessment visits to a representative number of abandoned sites to characterize the nature of contamination and to define potential exposure programs. Government assistance will be required to resolve legal barriers that presently exist and which impede forward movement on site remediation programs. Recognizing that soil removal and replacement strategies may pose financial obstacles to remediation, ILMC will be working with the international scientific community to determine the suitability of alternative approaches for interim management of contamination at specific sites. The principal remediation strategies to be evaluated include:

Removal of contaminated soils and replacement with uncontaminated soils, or removal of soil followed by decontamination and return of the treated soils to the original site;
Geochemical transformation of contaminants at abandoned sites through thermal, biological and chemical treatment methods;
In situ extraction and separation techniques; and
In situ stabilization and containment strategies

The range of treatment options that will be applicable at a given site will be dictated by site-specific geochemical and climate parameters. Indeed, a single technology and/or methodology may not be adequate to effect remediation at any given site. Thus, the guidelines will define a decision tree work plan, whereby different treatment technologies that can be integrated so as to reduce the risk of lead exposure.

In 1998 ILMC staff began working with the Center for Russian Environmental Policy (CREP) to identify industrial sectors for inclusion in a multi-sector Pilot Program. These activities were to be structured within the context of the activities of the State Committee for Environmental Protection (SCEP) of the Russian Federation. Potential risk reduction needs identified were associated with primary lead production, copper smelting, waste disposal in the lead crystal industry, and occupational exposures and environmental emissions associated with battery manufacturing and recycling.

Initial ILMC visits to Russia to conduct field monitoring at candidate industrial sites were scheduled for 1999. Unfortunately these scheduled assessments coincided with the initiation of NATO air strikes in Kosovo and anti-Western demonstrations and were thus delayed. To further complicate matters, the State Committee for the Environment was eliminated by the Federal government in May of 2000. As a result, Pilot Program activity in Russia focused upon the battery manufacturing and recycling industry sectors. Memoranda of Understanding had previously been established with battery manufacturing facilities in Russia, with agreed objectives to reduce levels of occupational lead exposure and to implement environmental management systems that included regimes to sample and monitor discharges from manufacturing facilities. Site visits to battery manufacturing facilities in St. Petersburg had been conducted, and experts from Russia had visited secondary lead and battery manufacturing facilities in the United Kingdom. This had permitted Russian experts to become familiar with British and EU methods for environmental sampling and for the control of occupational exposure. Training was also provided in the use of portable analytical equipment for the determination of occupational blood lead levels. Instrumentation provided by ILMC was then used at Russian facilities and established that some occupational exposures were excessive and in need of reduction. The engineering controls and personal protective equipment required to effect the desired exposure reductions were identified and arrangements made for necessary technology transfer.

Simultaneous with this was the establishment of an agreement between ILMC and the Russian organization, Electrozariad. Electrozariad was uniquely positioned as a partner for the execution of a risk reduction program. Based in Moscow, Electrozariad was formed in 1991 from the former Soviet Union's Ministry of Electrotechnical Industries by the leading battery manufacturing companies of the new Russian Federation. Electrozariad's main activities involve coordinating the procurement and distribution of industry's raw materials, especially scrap automotive and industrial lead acid batteries. Implicit in this is the transportation of finished products from the Russian battery manufacturing industry to customers, development of an investment program for the various manufacturing and smelting facilities in the Russian Federation, establishment of international cooperation with the world's lead acid battery industry, and serving as liaison between industry and the government of the Russian Federation. In 1998 Electrozariad had initiated a program to develop additional sources of raw material for battery production, particularly scrap lead. One source that is now recognized as important is the recovery of used automotive batteries that were previously either discarded or collected and sent to land fill. Electrozariad was instrumental in the development of a battery infrastructure collection system in Moscow that successfully increased the collection rates for used automotive batteries for shipment to secondary smelters.

ILMC and Electrozariad have entered into a formal working arrangement to assist in the expedited reduction of occupational lead exposure in the Russian Federation's battery manufacturing and secondary lead industry. The specific objectives of the Memorandum of Understanding recently signed include, 1) reduction of occupational exposures and environmental lead emissions where necessary; 2) the introduction of internationally recognized exposure assessment methodologies and measurement techniques for monitoring environmental emissions; and 3) the development of environmentally and socioeconomically sound policy options and community-based intervention programs to reduce lead exposure at selected locations. The Pilot Program being implemented will serve as a demonstration project for the Russian lead industry. Methodologies proving to be successful will be shared with both Federal and local government agencies.

Electrozariad is now working with ILMC to extend their successful Moscow Pilot Program to cover 19 regions in the south and southeastern regions of the Russian Federation. Electrozariad's strategic plan includes the development of infrastructure and industrial facilities to collect, segregate and recycle used automotive and tractor batteries estimated to contain some 60,000 tons of lead. The first phase of the project involves information sharing and gathering, environmental sampling and occupational exposure monitoring. Manufacturing process information will be combined with environmental assessment data and collated at the various plants so as to identify individual facilities that are significant point sources for lead. ILMC is serving in a technical support capacity to this study and will be advising on community intervention aspects of the project.

Significant logistical challenges are posed by the situation in Russia. The area in question covers approximately 1,200,000 square kilometers in which there are 7 million vehicles generating about 2.5 million used batteries per year. A growth rate of 9.6% in the generation of scrap batteries is projected and, if proven true, will result in the need for a collection infrastructure capable of capturing 5.5 million used batteries each year over a wide geographical area. The battery collection infrastructure systems that existed prior to the adoption of market reforms in Russia succeeded in collecting only 35-40% of the spent batteries. A plan has thus been devised to divide the large collection area into 15 manageable collection zones, each with its own collection infrastructure and an appropriately sized battery breaker. Provisions are further being made for separation of the battery components locally, followed by shipment of lead bearing materials to a common recycling facility. Investment of approximately $30-38 million (US) is estimated to be required for this ambitious effort and ILMC has been assisting in both the logistics of the battery collection scheme and the development of a realistic business plan for the project. ILMC is also providing guidance on the technologies used for the different components of the system and the environmental control systems that will be employed.

Following ILMC visits to Moscow in May, the Public Health Ministry approved in principle new rules for occupational exposure to lead, including biological monitoring. Details remain to be resolved with respect to the exact monitoring procedures and exposure limits that will be adopted. Towards this end, ILMC is working towards the establishment of a system that will:

Monitor, collate and evaluate ambient air lead levels at different sites;
Sample selected groups of occupationally exposed workers to determine correlations between methods used for monitoring lead exposure in Russian and those employed in the EU;
Conduct trial testing of different types of personal protective equipment; and
Test the adequacy of plant ventilation systems and the develop recommendations for improvement; and
Sponsor workshops focused upon occupational health, safety, and the training of medical personnel.

To further these goals, additional technical exchange visits have been arranged for Russian personnel to visit EU facilities to gain training in the laboratory and field analytical methodologies that will be required for this ambitious effort. Additional blood lead monitoring equipment has been provided by ILMC for use in Russia so as to facilitate the establishment of occupational exposure baselines.

In mid-1999 ILMC received multiple inquiries from Lima, Peru regarding material handling procedures appropriate for lead-containing mineral concentrates. Subsequent to this, the US Environmental Protection Agency advised ILMC that the US Centers for Disease Control, with funding from the US Agency for International Development, was working with the Peru public health agency (DIGESA) to determine levels of lead exposure in the general population of Lima. Excessive general population exposures had been detected near concentrate storage facilities at the Port of Callao just outside of Lima.

Preliminary discussions were held regarding ongoing US AID funded studies in Lima and, at the suggestion of US AID, contacts were then made with the public health agency in Peru. In late 1999 ILMC received a draft copy of documentation describing blood survey data for Lima and the nearby Port of Callao. General population blood lead levels in Lima averaged approximately 7 µg/dL. However, excursions well above this were reported in the vicinity of storage areas for mineral concentrates.

ILMC staff made an initial assessment visit to Lima in January 2000. A series of exploratory meetings were also held with industry and government representatives to evaluate the feasibility of establishing a cooperative project to reduce lead exposure risks associated with concentrate storage in the Port area. Preliminary inspections were conducted of concentrate storage facilities and provisional recommendations made with respect to changes in material handling procedures that might reduce levels of fugitive dust emission. Occupational hygiene procedures at the warehouses were of varying degrees of sophistication - occupational health issues were thus judged to be potentially appropriate for inclusion in a risk reduction effort.

Subsequent to this assessment visit, meetings were convened with the mining industry, an industry coalition of warehouse operators, DIGESA, US AID and the Ministry of Energy and Mines. Both industry and government expressed the desire to develop a proactive cooperative solution to the problems associated with fugitive emissions from concentrate storage and transport. The government agencies further considered it probable that the problems being encountered in Callao might have parallels elsewhere in Peru and Latin America. ILMC guidance was requested to devise a series of interim and long-term risk reduction efforts.

Noting that multiple sectors were planning or implementing exposure intervention strategies, but that coordination between the different sectors was minimal, ILMC negotiated a Memorandum of Understanding wherein government Ministries and industry sectors would work together to resolve lead exposure problems in the Port area. Issues included in the Memorandum of Understanding encompassed the reduction of fugitive emissions from concentrate storage areas, determination of occupational exposure levels, and the implementation of appropriate occupational exposure control and environmental emission control measures as needed. Over the course of the next several months, working arrangements were expanded to also include the Port Authority in Callao, railway service companies, and the Municipality of Callao. Opportunities for cooperation with outside agencies were identified, including assistance programs with the British Columbia Ministry of Energy and Mines and the Canadian International Development Agency. Following a series of visits in the first half of 2000, the various concerned parties agreed to form a cooperative multi-stakeholder "Roundtable" to address the lead exposure problems first identified in 1999. ILMC was asked to facilitate the activities of this Roundtable as the participants sought to:

Achieve tighter coordination between government ministries and different segments of the private sector;
Prevent duplication of effort and achieve more cost-effective allocation of resources;
Provide an independent technical review process for improvement plans resulting from the Roundtable.

The Roundtable now meets on a bi-monthly basis with ILMC, serving as a facilitator at the meetings. The meeting participants have embarked upon a program to monitor and reduce fugitive dust emissions from concentrate storage areas, develop environmental monitoring programs to evaluate the efficacy of different risk reduction methods, evaluate occupational exposure levels and to implement industrial hygiene programs as appropriate. Working groups were established to coordinate efforts to achieve each of these goals between the Roundtable meetings. To date, multiple interim exposure reduction measures have been implemented. Stored concentrates are now maintained in covered piles and air/dust fall monitoring has been implemented so as to monitor the effectiveness of the measures undertaken. Improved procedures for the loading and unloading of concentrates have also been developed. A consortium of mining, transportation, and concentrate storage facilities is further developing options for construction of modern concentrate storage and transport facilities modeled upon those in place in OECD countries.

The final outcome of the Peru Pilot Program is expected to have multiple beneficial impacts. Existing regulatory structures in Peru are not specifically designed to control occupational and general population exposures to lead. The principles being developed in the Roundtable process will thus have applications for multiple industry sectors in Peru. In addition, the problem of fugitive emissions associated with concentrate storage and transport are expected to be relevant to other port facilities in Latin America. This aspect of the Pilot Program may thus serve as a model for change in multiple countries in this region.

Although the design and implementation of intervention procedures through the Roundtable process remains the focus of ILMC activity in Peru, several additional issues are also being addressed. Existing programs for maintaining adequate analytical quality control and quality assurance for lead analysis are in need of improvement. ILMC is thus working with government ministries and industry to develop more reliable analytical capability for environmental assessment and general population exposure monitoring. Matters of medical intervention have also emerged to be of concern. ILMC is thus making provisions for training in the diagnosis and treatment of acute lead intoxication in children.

Existing ILMC Pilot Programs have permitted exploration of the "levers for change" that are effective for improving the environmental performance of industry sectors in a variety of cultural and socioeconomic contexts. In accordance with recommendations made by the independent Policy Advisory Group of ILMC, future Pilot Program activity will build upon these experiences to explore systemic approaches that can be applied for capacity building and risk reduction.

Discussions are ongoing with several international agencies and organizations to identify new Pilot Program opportunities that would permit the implementation of risk reduction on a regional basis and/or in concert with financial assistance vehicles that provide support for the capital expenditures required for the construction of new facilities and/or the introduction of new technologies. For example, in concert with the Basel Secretariat, consideration is being given to participation in analytical studies defining scrap lead acid battery flows in Latin America. Current analyses suggest that, for many countries, the quantity of used lead acid batteries generated may not be sufficient to sustain an economically viable recycling facility. However, the combined waste generation of multiple countries in a geographic region might provide the necessary level of material flow required for economic viability. The establishment of regional battery collection infrastructures, and regional recycling centers, may thus be explored.

In other instances, the volume of scrap battery generation is likely adequate to support an economically viable recycling industry. However, the initial capital costs associated with the construction or modification of recycling facilities with appropriate environmental performance characteristics can pose an obstacle to environmentally sound recycling. ILMC is thus engaged in discussions with the International Lead Zinc Study Group regarding the initiation of projects would attempt to arrange financial assistance for countries considering the construction of new facilities and/or the introduction of new recycling technologies. Geographic regions under consideration for this effort include Russian and the ASEAN region. Given that potential participants in either of the preceding efforts would require guidance on the environmental performance characteristics of different recycling technologies, ILMC has reached agreement with the United Nations Environment Program for the preparation of technical materials that describe the different processes that can be employed for lead recycling and technological issues associated with assurance of adequate environmental performance. This latter effort recognizes that the optimal technologies that might be employed by countries will vary as a function of both anticipated quantities of feed material and existing regulatory frame works. The engineering controls and environmental management systems associated with different technologies (e.g. pyrometallurgical versus hydrometallurgical) further dictate different strategies for controlling occupational exposure and environmental emissions. The technical materials would thus provide countries with an objective guide to the different options available for recycling and the measures that would need to be undertaken so as to ensure sound environmental performance.

The Green Lead™ Project is a proactive product stewardship program based on the sound management of materials and products in the Lead life cycle. Within the concept of Green Lead, sustainability is achieved by:

Green Lead™ recognizes that the vision of sound product chain management requires active and open collaboration and cooperation between the different stakeholders, companies, and industry leaders throughout the product’s life cycle.

The Green Lead™ Project builds on the principles set out in the sustainable development charter of the International Council on Mining and Metals (ICMM) and the Lead risk reduction programs of the International Lead Management Centre (ILMC).

Green Lead™ product stewardship manages the impacts of Lead and Lead products, such as Lead Acid Batteries (LAB), throughout the entire life cycle from the Lead mine through the product chain from manufacture, to use, and recycling.

Traditional environmental management systems focus on individual companies or specific sites mitigating or controlling environmental impacts. Green Lead™, however, extends product responsibility to all those involved in the life cycle; including designers, suppliers, manufacturers, distributors, retailers, consumers, recyclers and regulators.

During the past twelve months the ILMC has been involved in a Pilot Scheme for the development and testing of an Assessment Tool for the determination of Environmentally Sound Management (ESM) in conjuction with the Secretariat of the Basel Convention.

For more information about the Green Lead Project, Green Lead Protocols and the Green Lead Assessment Tool for Environmentally Sound Management, log into: www.greenlead.com.